ONTARIO Court File Number Ontario Court of Justice 267/13 (Name of Court) at 425 Grand Avenue West, Chatham ON N7M 6M8 Form 14A: Affidavit (General) (Court office address) dated January 30, 2014

Applicant(s) Full legal name & address for service — street & number, municipality, Lawyer’s name & address — street & number, municipality, postal code, postal code, telephone & fax numbers and e-mail address (if any). telephone & fax numbers and e-mail address (if any). Chatham Kent Children’s Services Loree Hodgson Harris 495 Grant Avenue West Barrister & Solicitor Chatham, ON N7L 1C5 Chatham Kent Children’s Services Tel: 519-352-0440; Fax: 519-351-2367 495 Grant Avenue West Chatham, ON N7L 1C5 Tel: 519-352-0440; Fax: 519-351-2367 Respondent(s) Full legal name & address for service — street & number, municipality, Lawyer’s name & address — street & number, municipality, postal code, postal code, telephone & fax numbers and e-mail address (if any). telephone & fax numbers and e-mail address (if any). Miriam Gittel Helbrants & Yachanan Laver Christopher Knowles 222 St. Clair Street, Unit 104 Barrister & Solicitor Chatham, ON N7L 3J4 518 Victoria Avenue Windsor, ON N9A 4M9 Tel: 519-252-0529; Fax: 519-255-1719 [email protected] Solicitor for the Respondent Parents

My name is (Full legal name) Miriam Helbrants We live in (municipality and province) City of Chatham, Province of Ontario

and I swear/affirm that the following is true: Set out the statements of fact in consecutively numbered paragraphs. Where possible, each numbered paragraph should consist of one complete sentence and be limited to a particular statement of fact. If you learned a fact from someone else, you must give that person’s name and state that you believe that fact to be true.

1. I am the respondent mother in this protection application and as such have knowledge of the matters hereinafter deposed to.

2. I make this affidavit in response to the affidavits of Kerry Rumble, Garnet Eskritt and Claudette Wyles all sworn December 17, 2013 and found at tabs 3, 4 and 5 respectively of the Continuing Record.

3. I deny the statements of Mr. Adam Brudveski found at paragraph 17 of Ms. Rumble’s affidavit; specifically I deny his suggestion that there is some edict in force requiring and authorizing the use of physical discipline in our community; this is a lie and an attempt to portray our community as something it is not. I declare that all what I wrote about this issue in Attachment 1 to form 33.b affirmed 28 January 2014 is true to the best of my knowledge.

4. Ms. Rumble’s statement at paragraph 45 of her affidavit is also false to the extent that it implies that the community as a whole endorses, accepts and regularly uses physical discipline on its children. I declare that all what I wrote about this issue in Attachment 1 to form 33.b affirmed 28 January 2014 is true to the best of my knowledge.

FLR 14A (September 1, 2005) www.DIVORCEmate.com Form 14A: Affidavit (General) (page 2) Court File Number 267/13 dated January , 2014

5. I do not use physical discipline on my children neither does my husband. I know for fact that physical discipline is not accepted in our community nor was it accepted in the past. I know for fact that the community do not believe in physical discipline and only encourage to educate the child in methods of love and explanation. The community believe that physical discipline contradict the commitment of the Torah of loving God and doing all commitments of the Torah only as result as love since physical discipline can cause afraid but can not resulted in love. I have never seen or aware of a parent or caregiver in the community that use physical discipline on a child.

6. With respect to Ms. Rumble’s statement at paragraph 46 of her affidavit it is completely false that there exists “a level of control by community leaders… which compromises the safety and development of the children.” The only knowledge Mr. Rumble has of this alleged fact is from what has read in Mr. Brudzveski’s transcript of evidence and perhaps from her contact with social workers from the Quebec agency; I am not aware of any evidence that exists from our time in Ontario which would support such an allegation. I declare that all what I wrote about this issue in Attachment 1 to form 33.b affirmed 28 January 2014 is true to the best of my knowledge.

7. Ms. Rumble states at paragraph 47 of her affidavit that the “investigation remains ongoing and additional materials will be filed.”

8. There have been no additional affidavits served on me since December 17, 2013; my husband and I have complied with all the terms of supervision that were ordered by Justice Fuerth on December 17, 2013 and there have been no new concerns identified by the Society since the without prejudice interim care order was made.

9. The public health nurse has told my husband and I she is not sure why the court order of December 17, 2013 requires us to engage the public health department for services as her opinion is that we do not require services from them.

10. My baby was delivered in December without any problems; he remains in my care and I am not aware of any concerns the Society may have with respect to his care.

11. There is no reason why the Society needs to continue its investigation into our family.

12. My version, which I told repeatedly to all social workers and to the police investors, on the cause of the mark, is true. It was, to the best of my knowledge, a result of the child Sheia marking on her face with a permanent marker and than my efforts to clean the ink stain. This all is true and I declare that I had not lie or hide any thing related to the mark or alleged bruise.

13. As far as I verified and researched the opinion of the doctors regarding the Mark, I did not see any official medical confirmation that it was in fact a bruise. However, it can be that my scrubbing on the sensitive skin of my child cheek (together with eczema and treatment eczema that my child had) caused some kind of light bruise. However it must to be very minor which I never notice it as a bruise. Of course I was not about to just over scrubbing the mark intently. However the definition "injury" to the mark is just outrageous me and is not backed by any medical confirmation.

14. I enclose as Exhibit “A” my correspondence with Dr. Newell, which includes a letter from Dr. Newell dated January 22, 2014. Dr. Newell was the hospital emergency room doctor who treated my daughter Sheia when the Society workers brought her to the hospital on December 12, 2013.

Form 14A: Affidavit (General) (page 3) Court File Number 267/13 dated January , 2014

15. As you can see from Dr. Newell’s letter of January 22, 2014, he confirms his earlier diagnosis which can be found at paragraph 37 of Ms. Rumble’s affidavit, which was that there was a 1-2 cm lesion that had the appearance of bruising and that she had diaper rash due to irritation however she had no ear infection. He used the term "I hence felt it was a bruise" rather than "confirmed".

16. It is clear from the letter of Dr. Newell that he never performed the cleaning test since he relied on the word of unidentified 'CAS worker' that stated to him that he or she already tried to remove the mark with no success. A fact that is missing from all 3 affidavits of three CAS workers in the case. I doubt in the level of reliance on this CAS worker's claim as well I am questioning the level expertise of such cleaning test if it was taking place.

17. Dr. Newell also indicates that his diagnosis of a bruise was partly based on the words of the unidentified CAS worker that claimed that she or he performed some kind of cleaning test prior to the arrival to the hospital. A fact that undermines the certainty of the doctor's diagnosis.

18. Furthermore Dr. Newell confirms in his January 22, 2014 letter that the issues he noted were minor and that he did not give an opinion as to whether the bruise constituted abuse or neglect.

19. Dr. Newell also confirms his earlier diagnosis that the children were generally in good health as was stated at paragraph 37 of Ms. Rumble’s affidavit.

20. I can not rule out the possibility that the intensive scrubbing of the ink stain caused some light bruise in addition to the remains of the ink stain. I consider this possibility, because I am not questioning the good faith nor the professionally of Dr. Newell and I respect Dr. Newell’s diagnosis that the mark may in fact be some minor bruising in addition to the remains of the ink stain and it was so minor that I did not get a notice of it. However I deny any allegation that this bruise is the result of abuse or neglect on my part, my husband’s part of that of any caregiver of my child.

21. I enclose as Exhibit “B” a letter from Dr. Rachel Rubinstein dated January 5, 2014.

22. Dr. Rubinstein is a dermatologist, her practice is located at the Jewish General Hospital, her contact info is Dermatology Clinic G-026 Jewish General Hospital, 514-340-8222 ext. 8272, her information can also be found at this website: http://www.medicine.mcgill.ca/dermatology/clinics_jewishgeneral.htm

23. My lawyer Christopher Knowles called Dr. Rubinstein’s office on January 27, 2014, I am advised and verily believe that a staff member of Dr. Rubinstein’s advised Mr. Knowles that she would let the doctor know he would like to discuss her letter of January 5, 2014 and obtain a CV.

24. I undertake to provide her CV to the Society and to the Court as soon as it is made available to my lawyer.

25. Dr. Rubinstein was Sheia’s doctor when we lived in Quebec and she had prescribed some creams for Sheia’s eczema that Dr. Rubinstein suggests could have been the cause for the mark on Sheia’s face. I also consider it as a factor that may be added to cause light bruise during the scrubbing of the Ink stain. However I deny any allegation that this bruise is the result of abuse or neglect on my part, my husband’s part of that of any caregiver of my child.

26. Also note that Dr. Rubinstein’s opinion after having treated a number of children in our community was that the children were “clean, well-cared for and behaving appropriately.”

Form 14A: Affidavit (General) (page 4) Court File Number 267/13 dated January , 2014

27. Dr. Rubinstein’s opinion is similar to Dr. Newell’s in that the children were generally in good health.

28. I enclose as Exhibit “C” a letter from Mrs. Pamela Baker B,A. (H), M.S.W. RSW. Dated January 29, 2014.

29. Mrs. Pamela Baker, professional social worker and psychotherapist, registered and credentialed with the Ontario college of Social Workers and Social Services Workers since 2012.

30. The Social Worker Mrs. Pamela Baker concludes her letter by stating as follows: "With regards to the above results of the Back Depression Inventory and the Back Anxiety which could potentiality. The client is currently reporting that she is not suffering from depression or anxiety which could affects her abilities to parent properly. Further assessment would have to be done by a professional psychologist."

31. In contradiction of what the CAS was about to insist in Subparagraph 5 of form 8B that "The mother has recently expressed emotional instability…". The conclusion of Social Worker Mrs. Pamela Baker makes any further involvement of CAS social workers as irrelevant in regards to their concerns about my emotional stability.

32. It is impossible for me as a private young mother to answer endless rumors, tales and allegations that the CAS bring up to make Lev Tahor as a cause of concern. And it will be just an outrage for me if the CAS will bring up even more of such stuff in my case. Even so, I take all efforts to answer all other issues that the CAS already bring up in "Attachment 1 to form 33B.1" affirmed 28 January 2014. I must note that I take efforts to address some of the issues that the CAS bring up it my case even that I don't understand the relevance of the issues to my case.

33. While I didn’t justify the legal\illegal tricking method of the CAS which mixes up in my private case claims and allegations that has been filed against the families of Solemani and Hayon, however in fact the vast majority of my court case by the CAS are preoccupied with those claims and allegations, so I am compelled to defend my case with answers that were originally written in regard of those claims and allegations.

34. I did apologies that all of the following exhibits are not withstanding all the usual standards required for affidavits, the persons who did express the arguments in the following exhibits did not yet sworn their arguments especially for this case, however this is due to technical shortage of time needed for such procedure.

35. I only include Exhibits from persons that permit the use of their writing for this particular case. All of them promised to swear the very same argument and to testify under oath and be crossing examined on their arguments if necessary.

36. I must note that the arguments of the CAS against Lev Tahor are even less withstanding the standards needed for testimonies in court. Not only the claims of the CAS against Lev Tahor were hearsay evidence, but even the supposed doctors' opinions and medical informations that regarded my children were all only hearsay evidence and non of them officially sworn and affirmed by the doctors themselves, so I don’t see it appropriate to the CAS to argue about those exhibits which their validation can not be doubted.

37. On this affidavit I will only make a use of arguments from objective figures which are not in way affiliated with the Lev Tahor community.

Form 14A: Affidavit (General) (page 5) Court File Number 267/13 dated January , 2014

38. "Exhibit D" Is an expert opinion submission of Professor Yaakov M. Rabkin who is Professor of Contemporary History at the University of Montreal (his expertise and resume attached to the exhibit), and is expert witness in Canadian and international courts. This expert submission was filed as evidence in chief in a family court in Israel, back in 2011, which judged similar allegation about the Lev Tahor community than located in Quebec.

39. Professor Yakov Rabkin did express on January 10, 2014, to Mr. Uriel Goldman, from the Directors of Lev Tahor, an oral permission to use the very same expert opinion as an exhibit in my case. He also noted that if the honorable court will see it necessary he will testify before the court regarding the same issues in my case.

40. In his expert opinion, Professor Yaakov M. Rabkin, stated about the children of Lev tahor: "all the children, however, appear normally fed and clad." This makes any extra concern about Lev Tahor children unreasonable.

41. Professor Yaakov M. Rabkin, also stated that "One can see a lot of reverence expressed to the community leader (or Rebbe), which is quite similar to what I observed in other Hasidic groups." This contradicts the alleged so-called "Level of control" of my father which the CAS sees as concern for the safety and development of my children.

42. Geography Professor Joshua Comenetz at the University of Florida, who completed the first estimate of the Hasidic population based on the U.S. Census, estimated today’s Hasidic population at about 180,000 in the United States alone back in 2006 (source: University of Florida news web site http://news.ufl.edu/2006/11/27/hasidic-jews/). Other estimations of Hasidic Jews population worldwide range between 500,000 and 1,000,000. To this end, since an objective expert describe the "Level of control" just as equal to other Hassidic groups, Lev Tahor children are under the same "Level of control" of hundreds of thousands other Hassidic Jewish children. Targeting Lev Tahor only about this issue should be considered discrimination.

43. "Exhibit E" is an article recently published by the University of Montreal; it is a press release and a public expert opinion by Professor Yaakov M. Rabkin, dated December 10, 2013, in light of claims and allegations steams from the high profile courts of the two families Soleimani and Hayon.

44. In his public expert opinion, Professor Rabkin insisted that he researched the Lev Tahor community for a decade, his research includes unannounced visits and interviews with individuals, and he never noticed any thing that can indicate abuse, violence or neglect.

45. Professor Rabkin further insisted that his decade long research on the nature of the Lev Tahor community as well on the character of the State of Israel, give grounds for the "antagonism" that the Zionist population have against Lev Tahor as well as for the actions of the state of Israel to dwell on rumors of allegation that are not in their jurisdiction.

46. Professor Rabkin hinted that Quebec's approach regarding claims and allegations against Lev Tahor may be subjective partly due to pressure by Israeli authorities and their supporters in Canada. A fact that makes a careful diligent review a must before relying on unverified allegation regarding Lev Tahor.

47. Professor Rabkin also shared his personal involvement in the long planning stages of the ultimate relocation of the community from Quebec, as he stated: "To avoid controls stipulated in the Quebec Public Education Act, they began planning a move to Ontario several months ago. They spoke to me about this when I visited them last summer with a PhD student in anthropology from Brazil."

Form 14A: Affidavit (General) (page 6) Court File Number 267/13 dated January , 2014

48. This revealing of Professor Rabkin on his part in the planning stages of the relocation several months before its actually took place is in total contradiction of subparagraph 8 of form 8B that says: "On Monday, November 18, 2013, the parents suddenly and without notice to the Quebec Child Welfare authorities fled the jurisdiction and arrived in the Municipality of Chatham-Kent…". Once again it shows the CAS is basically ignorant on any issue relating to Lev Tahor.

49. "Exhibit F" Is an expert opinion submission of Dr. Bernard Fryshman Ph.D. in physics, Professor at New York Institute of Technology for more then 50 years. Since 1973 on the leadership of the Association of Advanced Rabbinical and Talmudic Schools. Professor Fryshman served two terms on the predecessor to the National Advisory Committee on Institutional Quality and Integrity, the body that advises the U.S. Department of Education on issues related to higher education accreditation and institutional eligibility for federal student aid programs. He also has served on committees of the Council for Higher Education Accreditation and the Association of Specialized and Professional Accreditors. (His professions and resume provided by the National Association of Independent Colleges and Universities is attached on the beginning of Exhibit F).

50. Professor Dr. Bernard Fryshman is often an expert witness or expert opinion in cases relevant to culture, education and Judaism. Including testifying before congressional committees. Since Professor Fryshman is Montreal native, he is well involved in the Montreal Jewish communities and was the expert opinion witness at the high profile court case of Québec (Procureur général) Vs. Académie Yeshiva Toras Moshe de Montréal (SUPERIOR COURT CANADA, PROVINCE OF QUEBEC, DISTRICT OF MONTREAL, No.: 500-17-057863-105 DATE: September 7, 2011) were the honorable Gérard Dugré granted, based on Dr. Fryshman's opinion, an order overruling the decision of the Quebec education ministry to require the Ultra orthodox Jewish Academy to immediately adopt the secular curriculum of Quebec.

51. Professor Dr. Bernard Fryshman has deep knowledge about the Lev Tahor community and particularly about the Grend Rabbi which is my father, from the time that the Lev Tahor community and my father lived in New York on the 1990's. Dr. Bernard Fryshman had been witnessed and involved in many episodes relating my father and Lev Tahor.

52. Since my father and the community moved to Quebec back in 2001, Dr. Bernard Fryshman was not able to meet my father or to visit the community, however directors of the community kept in touch with Dr. Frysman from afar seeking his advice on education issues. Even Dr. Frysman is not being able to serve as an eye witness on to the time that the community was in Quebec, he have a reasonable critical sense on the allegations about Lev Tahor.

53. This expert opinion submission of Dr. Bernard Fryshman, originally written by him to be published in US Jewish magazines, Dr. Fryshman analyse the actual 28 subparagraphs that were to use as grounds for the DYP claim that the security or development of the children of Lev Tahor are considered to be compromised.

54. Professor Dr. Bernard Fryshman did express on January 30, 2014, to Mr. Uriel Goldman, from the Directors of Lev Tahor, an oral permission to use the very same public expert opinion as an exhibit in my case. He also noted that if the honorable court will see it necessary he will testify before the court regarding the same issues in my case.

55. Addressing the concerns on those 28 subparagraphs, is much more relevant then addressing the 90 subparagraphs of paragraph 17 on Ms. Rumble’s affidavit in my case, since those 28 paragraphs are

Form 14A: Affidavit (General) (page 7) Court File Number 267/13 dated January , 2014

representing the opinion of the DYP at the very final days of Lev Tahor in Quebec. Any new issues and concerns raised by the DYP after Lev Tahor left Quebec, including, but not limited to, the vast majority of the 90 subparagraphs on Ms. Rumble’s affidavit, which are in fact based on the testimony of Adam Brudzevsky on December 27, 2013, should be questioned first why didn’t the DYP make a use of them in their original motions. Giving the fact that the DYP was already in close contact with Adam Brudzevsky for a long period of time, for the DYP to decide over night to believe him on any issue they didn’t believe him before, seems motivated by frustration over the move itself.

56. Regarding the ground for concern of the DYP in subparagraph 3.3 giving that: "The legitimacy of the community “Lev Tahor” is not recognized by other Orthodox Jewish communities", Dr. frysman reacts in his expert opinion: "that This signals a new area of concern for all religious bodies. If the legitimacy of a religious community is to be predicted by its ‘recognition’ by another group or groups, then all religious bodies are threatened."

57. The above expert opinion proves that the request of the CAS in my case, which is based largely on those Quebec court filings as well as a Quebec order to locate and deliver my children which is based on similar claims, is in fact a undoubted violation against the freedom of conscience and religion guaranteed by the Canadian Charter of Rights and Freedom section 2.

58. Regarding the ground for concern of the DYP in subparagraph 3.4 and 3.10 giving that: "The children are not in school; The boys attend, several hours a day, a place where religious education is given to them", Dr. frysman reacts in his expert opinion: "These mutually contradictory findings (along with findings 3.5, 3.6, 3.7, 3.8, 3.14) suggest that the reason the children are to be taken from their families is because of the nature of their education rather than because of abuse or neglect. This, by the way, is the reason the Mennonites also fled the Province of Quebec."

59. Once again, the above expert opinion proves that the request of the CAS in my case, which is based largely on those Quebec court filings as well as a Quebec order to locate and deliver my children which is based on similar claims, is in fact yet another undoubted violation against the freedom of conscience and religion guaranteed by the Canadian Charter of Rights and Freedom section 2.

60. Regarding the ground for concern of the DYP in subparagraph 3.13 giving that: "Children react negatively by fear, distrust and disgust when put in contact with external people to the community and their way of life" Dr. frysman reacts in his expert opinion: "Compare this claim with the observation by Canadian Jewish News reporter Paul Lungen who, unlike most other journalists, took the trouble to explore the Lev Tahor community first hand and in depth. Writing in the January 20, 2014 edition of the newspaper, Lungen observes: (beginning of citrate) In a 2-1/2-hour visit earlier this month to the Lev Tahor shtetl, located on the outskirts of Chatham, I found dozens of smiling children, curious about the newcomer and eager to have their photos taken. Boys were in school, studying Judaic subjects. Boys and girls are educated separately. (end of citrate)."

61. The above expert opinion proves the Quebec DYP in general as ignorant regarding Lev Tahor or at the alternate bias, and suggest the children were in fact afraid of the Quebec DYP workers only as result of the Quebec DYP unwarranted showcase apprehension of five children of the community in August 14, 2014. And this is yet another reason I'm asking for a order to immediate relief me and my children from the CAS which made the same showcase apprehension on my two children.

62. Regarding the ground for concern of the DYP in subparagraph 3.17 giving that: " Most of the girls in the community suffer from fungal infections in the feet, directly in connection with the obligation to wear stockings, days and nights" Dr. frysman reacts in his expert opinion: "Now read this report by Assistant

Form 14A: Affidavit (General) (page 8) Court File Number 267/13 dated January , 2014

Professor (McGill University) of Dermatology, Rachel Rubinstein, MD, FRCPC: My name is Rachel Rubinstein, MD, FRCPC, and am assistant professor of dermatology at McGill University and practice out of the Jewish General Hospital in Montreal. I was asked to visit the Lev Tahor community in St. Agathe, Quebec on November 14, 2013 to evaluate and treat their dermatologic problems. In general, I found the children to be clean, well-cared for and behaving appropriately. I was impressed by the warmth of the community and concern of the parents for the well-being of their children. Overall, I evaluated 61 patients, the majority of which were children, at the Lev Tahor community. The most common problems I encountered were onychomycosis (nail fungus), stopic dermatitis, acne and warts. These are typical clinical problems I routinely encounter in my dermatologic practice. These are relatively benign conditions, many of which spontaneously resolve in early adulthood. It is important that I emphasize, unequivocally, that these problems do not reflect parental neglect or abuse. As such, there is absolutely no indication for intervention by child welfare authorities regarding these minor skin conditions." (As I noted above, the evidence of the CAS in my case regarding the doctors opinion on the alleged bruise of my child Sheia are not less hearsay evidence).

63. Regarding the remaining grounds for concern of the DYP, Dr. frysman reacts in his expert opinion: "The other findings need no further comment: every person of faith will find good reason to object to a government agency interpreting religious practices as justifying placing a child in foster care. Foster care for abused children is a necessity; taking a child which is in a caring relationship from its mother is traumatic. Reportedly many children so removed never recover and remain troubled for life. Fourteen Lev Tahor children are threatened with this draconian edict, for reasons of their culture and faith – and for no other reason".

64. "Exhibit G" is another public expert opinion written by Professor Dr. Bernard Fryshman, and this time a reaction to the testimony of Adam Brudzewski against Lev Tahor before the Quebec court on November 27, 2013, which is summarized in the 90 subparagraphs of paragraph 17 on Ms. Rumble’s affidavit in my case.

65. Professor Dr. Bernard Fryshman did express to Mr. Uriel Goldman, from the Directors of Lev Tahor, an oral permission to use the very same public expert opinion as an exhibit in my case. He also noted that if the honorable court will see it necessary he will testify before the court regarding the same issues in my case.

66. In this expert opinion, Dr. Fryshman analysis the testimony of Adam Brudzewski from the point of view of an expert in culture, education and Judaism. Dr. Fryshman shares his examination of the original testimony from the court transcripts, and draws his conclusion that "there is no doubt that there is much about the community which is displeasing and discordant to the 21st Century ear. But this is precisely the point. Lev Tohar is a community of Jews that has elected to emulate an approach to life which is characteristic of the 18th century in certain respects. There is not a shred of evidence of any physical mistreatment of adults - or abuse of children. The community obeys the laws of the Torah - and respects and obeys the laws of Canada. In the end, that’s all that should concern us."

67. More elaborated, Dr. Fryshman argues in his expert opinion as follows: "We will put aside testimony regarding the nature of the educational program, the emphasis on young people marrying before the age of 16, the anti-Zionism of the community, or the fact that everyone speaks Yiddish. After all, an excellent case can be made for the intellectual and critical thinking outcomes of Lev Tohar’s educational activities. The issues relating to freedom of religion did not belong before this Court. Government has no business interfering in the free exercise of religion, and the Province of Quebec is extremely sensitive to this."

Form 14A: Affidavit (General) (page 9) Court File Number 267/13 dated January , 2014

68. The above expert opinion proves that the request of the CAS in my case, which is based largely on this testimony of Adam Brudzewski, is in fact an undoubted violation against the freedom of conscience, religion, thought, belief, and opinion guaranteed by section 2 of the Canadian Charter of Rights and Freedom.

69. In this public expert opinion, Dr. Fryshman also noted that "the provincial authorities were certain that Brudzevski’s testimony would establish that Lev Tahor (as Rabbi Helbrans’ community is called) is abusing children and the entire movement is a cult. Only it didn’t quite turn out that way… The sworn testimony was highly revealing. First and foremost it confirmed that Lev Tahor is not a cult. People come and people go; the community lives in the middle of an urban setting, and there are members who have access to the Internet. There is no question that Rabbi Helbrans is a charismatic leader, but any indoctrination that takes place is squarely within the bounds of Halacha (Jewish law – M.H.). The fact that the societal overlay is that of a Jewish community 200 years ago doesn’t make the community a cult…"

70. Further in his expert opinion, Dr. Fryshman noted: "Also of interest is the fact that after all the accusations, the complaints to provincial authorities, the reports of child abuse, and the countless visits and investigations carried out in St. Agathe, the Province had to rely on Adam Brudzevski, a young man with an uneven, if not troubled past, as the basis of its presentation to the Youth Commission… It’s noteworthy that Province of Quebec authorities could not bring a single example of drugs or crime associated with the young people of Lev Tahor. They were trying to build a case against the community, and they were reduced to grasping at straws."

71. As Exhibit "H", I enclosed a letter from Mr. Harold boss and his wife Mrs. Diane Boss from Monroe, NY. Mr. Harold boss is a psychometrician in the area of testing and measurements for New York State for nearly 40 years.

72. Mr. Harold boss and Mrs. Diane Boss, who are not members of Lev Tahor, have a wide knowledge of what is happening in Lev Tahor in the last 20 years; their daughter and her family have been members for 20 years, and they had visited them on many occasions, both planned and spontaneous.

73. A more important fact is that Mr. Harold boss and Mrs. Diane Boss are the grandparents of Adam Brudzewski, which the request of the CAS in my case is based largely on this testimony against Lev Tahor on November 27, 2013 before the Quebec court.

74. Mr. Harold boss and Mrs. Diane Boss, who had a close relationship with Adam Brudzewski even after leaving the community Lev Tahor, are sharing in this letter addressed to the Honorable court their knowledge regarding the disordered personality of Adam Brudzewski that "compelled him to viciously turn not only his own parents-in-law, but on the community that tried to help him, as well."

75. As Mr. Harold boss and his wife Mrs. Diane Boss stated in the end of their letter, they are willing and ready to testify before the honorable court under oath on the entire content of this letter, if the honorable court will see it necessary. However the shortage of time did not to allow prepare a formal and sworn affidavit for this content.

76. In their letter, Mr. Harold boss and his wife Mrs. Diane Boss stating as follows: "His mother told us that while still in Denmark he insisted on finding a wife who wanted to go in the “old-fashioned way, and dresses in black.” That search lead him, via India, Haight-Asbury, and many stops in between, to Lev Tahor. There, his superior intelligence facilitated his ability to assume any persona he chose, and in short order he fit right in and excelled. Once he achieved his goal, our grand-daughter, he turned

Form 14A: Affidavit (General) (page 10) Court File Number 267/13 dated January , 2014

against the community that befriended him, and his duplicity was revealed. Please understand that this is not mere conjecture. While living in Monsey, NY, Mr. Brudzevsky told me that he went to Lev Tahor to find a wife and then to leave. This was confirmed by his mother. There was never an intention to embrace the life practiced in Chatham, but to use that unsuspecting community."

77. Regarding the so-called "escape" of Adam Brudzewski and his wife from Lev Tahor, which is described in pages 108-110 of the Quebec court transcripts, and summarized in subparagraph 86 of paragraph 17 on Ms. Rumble’s affidavit in my case, Mr. Harold boss noted: "there was simply no need to plan an elaborate escape, after all, from an open, residential neighborhood from which the member of Lev Tahor travelled daily without impediments or restrictions. His personal restrictions grew from the fantasy developing in his mind, and dominating his thoughts."

78. Further in his letter, Mr. Harold boss describes the story of Adam Brudzewski after leaving Lev Tahor: "From Lev Tahor, Mr. Brudzevsky and his wife went to Denmark, where his his mother, a clinical psychologist, revealed that he needed her professional help. She supported the young couple and their newly born son, while trying to entice them into self-sufficiency. Her efforts failed, and soon the Brudzevsky family was on its way to the US. From Denmark they came to our town of Kiryas Joel. An insight into Mr. Brudzevsky's psychological difficulties emerge when one views his difficulty providing for his family. I have a daughter living nearby, and the Brudzevskys planted themselves in her basement, quite content to let my daughter care for their infant, as well as clothe, feed and shelter them. We were witness to this. In desperation, my daughter's husband found them an apartment in Monsey, NY. for which Mr. Brudzevsky's mother paid the rent. Periodically, she would call my son, who lived nearby, to motivate her son from his indolence. Curiously, Mr Brudzevsky's mother once flew from Denmark to visit him in Monsey, but ended up staying at my son's house, because, “I couldn't stand it anymore.”

79. According to Mr. Harold boss, not only Lev Tahor has been "diagnosed" by Adam as a "cult". In his words: "Interestingly, Mr. Brudzevsky began attending a well-respected school in Monsey, NY designed for married men, and after a brief period he told me that that school, too, was becoming a cult, and thus he could no longer attend. It became obvious to both my wife and I that this young man displayed some significant psychological problems, but we kept silent."

80. Furthermore in his letter, Mr. Harold boss describes many facts of Adam's behaivor before and after leaving Lev Tahor, all which describe a troubled and disordered personality and a nature of destroying lives for the innocent.

81. The conclusion of Mr. Hrald Boss in his letter is: "In my estimation, Mr. Brudzevsky represents the second of Lev Tahor's major errors in judgment. They saw someone in need, tried to help, and found themselves fighting for their own existence."

82. Exhibit "I" of my affidavit is a letter ea letter from Mrs. Bonnie Wood from Seattle, Washington, originialy written to the CAS after the apprehension of my children in December 2013.

83. Mrs. Bonnie Wood lived in the Lev Tahor community of Lev Tahor for 2 1/2 years. She is a certified trainer of Neural Linguistic Programming; She did Psycho-Neuro Biology; She have studied and taken classes on abuse.

84. In her letter she states: " I have known Miriam Laver since she was a child. She is a loving, intelligent, caring person, and is a wonderful concerned and caring mother. I have always admired her high degree of emotional intelligence, and her ability to communicate and relate well to people. Miriam’s children

Form 14A: Affidavit (General) (page 11) Court File Number 267/13 dated January , 2014

are testimony to her skill as mother…. Miriam Is, if anything, an example of what a good mother is. I have never seen any bruises, cuts or welts on either of her children. I have never seen any sign of abuse on her children. If all children who have a slight mark on their face were taken away from their parents, we would have no children in their birth homes. Miriam is a delight. Her mother-in-law frequently helps with the children. Her family is everything to her. She keeps them clean and addresses any health issues that they may have. They are her pride and joy. She values them so much, of course she takes good care of them. Miriam is a wonderful mother."

85. I do not intend to further answer of defence other "concerns" that do not regard to me as a private responsible mother. All such issues that regard community policies have to be addressed to the community directors and they are to be blamed or praised for any community policy and they are to defend\deny\confirm\explain any such.

86. The community directors are, Mr. Uriel Goldman, Mr. Mayer Rosner, and Mr. Nachman Helbrans.

87. The community directors who was on the past in the opinion of cooperating with the CAS as a sign of trust, did change their approach, largely because their disappointment of the CAS behavior in my case. Even so, the community directors did express that they are still ready to talk and discuss with the CAS any concern they have or might have in the future regarding community policies. However they explain to the CAS that six months of investigation on each and every individual adult and minor from every angle, by the Youth Protection in Quebec and than by the CAS in Chatham, is just as enough to draw conclusions. The community directors single out themselves as responsible before justice on any thing steaming from community policies in favour of relax and normal life of the innocent mothers' boys and girls.

88. A letter from the above-mentioned community directors, namely Mr. Uriel Goldman, Mr. Mayer Rosner, and Mr. Nachman Helbrans, to the board of directors of the CAS of Chatham-Kent, dated January 27, 2014, is enclosed as Exhibit "J" to my affidavit.

89. In this plea to the CAS, the community directors explaining in detail the approach of the mothers, fathers and children of the Lev Tahor community regarding the excessive involvement of the CAS in their private lives,

90. It must be noted, that the CAS directors assured the community on January 27, 2014 to give their response to this letter as soon as possible; however, to this day, the community had not received any response from the CAS.

91. It light of the above spirit between the community and the CAS, I am concern regarding the objective view that CAS will have from further supervision on me. I ask the honorable court to release me from that. If in fact there is concern with all Lev Tahor families and they should be under supervision orders I will be with them too in the future. However for this case, I don’t see justification to have unnecessary intervention in my family life.

92. If the honorable court see it necessary to have an adjournment on this case, I will ask the court to issue a temporary order to release me and my husband from any obligation to the CAS intervention that was include in the decision of the honorable court on the 17th of December 2013. The only condition that I see appropriate on the interim order is that I and my children will be bound not to change our address outside of the jurisdiction with out permission of the court (not the CAS) and an obligation to notify the court Clerk (not the CAS) of any change of address within the jurisdiction.

Form 14A: Affidavit (General) (page 12) Court File Number 267/13 dated January , 2014

93. All what I wroth in this affidavit, as well in "Attachment 1 to form 33B.1" affirmed 28 January 2014, is true to the best of my knowledge.

94. I make this affidavit in response to the Society’s temporary care and custody motion and for no other improper purpose.

Put a line through any blank space on this page.

Sworn/Affirmed before me at: Chatham (municipality) in Province of Ontario (province, state or country) on January , 2014 MIRIAM HELBRANTS (date) (This form to be signed in front of a lawyer, justice of the peace, notary public or commissioner Commissioner for taking affidavits for taking affidavits.) (Type or print name below if signature illegible.)

THIS IS EXHIBIT "A" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 1/28/2014 Gmail - Patient Diagnosis - Clarification

Miriam G Helbrans

Patient Diagnosis - Clarification

Miriam G Helbrans Fri, Dec 20, 2013 at 8:14 AM To: [email protected], [email protected], [email protected]

With the help of G-D

Dear Dr. Newell,

My name is Miriam Gittel Helbrans.

I am the mother of Sheia Baila Helbrans (D.O.B. July 13 2012).

On December 12 2013, during a visit from the children society aid at the home of my daughters babysitter, there was notice of a mark on my daughters left cheek. Since it looked like an injury, it caused concern for the workers. The workers decided that they will apprehend my daughter as well as my son for 5 days pending a court hearing.

In order to better present my question, I would like to copy a few relevant sentences from the affidavit that was written on Dec. 13 2013 by the social worker, Garnet Eskritt.

(Paragraph 5) " On December 12, 2013 I attended at the home of Batsheva Alter and Pinchas Feder.....I approached the stroller and observed a small female child sleeping in the stroller. Mr. Feder advised me they were babysitting for their neighbor Miriam Helbrants.....Mr. Feder stated to me the that the child's name was Sheia."

(Paragraph 6) "As I continued to interview Mr. Feder, approximately thirty minutes later the child Shia woke up. As Sheia had moved in the stroller, I was able to observe what appeared to be a dime size bruise located on her left cheek, adjacent to the left corner of her mouth. I requested that Ms. Rumble observe the injury."

(Paragraph 7) "Ms. Rumble and I questioned Batsheva Alter is she was aware of the injury to the child. Ms. Alter stated that is was not an injury that the mother had informed her that the child Sheia had marker on her face Ms. Alter went on to explain that the mother told her that, the father had purchased markers for the children to play with but had not realized they were permanent markers. Sheia had been playing with a marker and had written on her face and hands. Ms. Alter stated that the mother had been able to get the marker off Sheia's hands but had been unable to wash it off her face. Ms. Alter explained that this occurred several days ago."

(Paragraph 16) "...I spoke briefly with the father, the father stated to me that he had not observed any injuries on the child Sheia. the father advised me that sheia had colored on her face with permanent magic marker. The father stated that last Friday, December 6, 2013, he had purchased markers but had not realized that there were both permanent and washable markers. The father stated he had purchased permanent markers. On Sunday, December 8, 2013, when he had returned home at approximately 9:00 p.m., the children were already in bad. The father stated that the mother had informed him that the child Mendel had been playing with the permanent markers and Sheia had gotten those markers and coloured on her hands and face.

(Paragraph 19) "on December 12, 2013, Chatham-Kent police constable Jennifer Jacobson and I conducted a https://mail.google.com/mail/u/2/?ui=2&ik=b875672a34&view=pt&search=sent&msg=14310250948b3207 1/4 1/28/2014 Gmail - Patient Diagnosis - Clarification videotaped interview with the father. The father disclosed information similar to that provided to me in the waiting room, Sheia writing on her face with permanent markers... The father explained that Sheia had sensitive skin and that they had seen a specialist in the past so they were very careful with her skin."

(Paragraph 25) "After Mr. Heath and I received the requested items from the father, we attended at the Chatham-Kent Health Alliance with Ms. Doran, Ms. Rumble and the children. The children were examined by Dr. Newell. Dr. Newell also confirmed to me that the mark on Sheia's left cheek was a bruise and not permanent marker. Dr. Newell di not observe any injuries on the child Mendel. Dr. Newell stated that with the exception of the bruises the children appeared generally in good health."

(Paragraph 26) " On December 21, 2013, Mendel and Sheia were placed in society foster care."

(Paragraph 28) "On December 13, 2013, Ms. Rumble and I spoke with the parents regarding the results of the investigation and to arrange access for the children. The parents were advised that the mark on Sheia's face was not magic marker and that the doctor had identified is it as a bruise. The mother continued to insist that the mark was made by a magic marker. The mother thought the colour or pigment had somehow absorbed into Sheia's skin. The mother said she had gently washed Sheia's face using warm water and her hand as the child had sensitive skin. The mother indicated to me that after washing Sheia's face, she had applied lotion to Sheia's skin. The mother denied pressing hard on the skin and continued to insist that it must of come from the markers. The father made no comment and stated that his wife would explain as her English was better than his. I mentioned to the father that his English was very good and that communication had been very good yesterday. The father remained very quiet throughout that interview."

(Paragraph 32) "The child Sheia Baila Helbrants has a medically confirmed bruise to the left cheek adjacent to the mouth. The parents are unable to present a plausible explanation for the injury"

After I laid out the relevant excerpt from the affidavit from Garnet Eskritt, I feel it is my obligation to point out my concerns and seek a clarification in regards to the case with my daughter. Without doubting your expertise or integrity as an Emergency Medical Director, I would like to verify a few points that, in my opinion, will help to clarify the issue of the mark on the cheek of my precious daughter, a clarification that is crucial for the determination of the best interest of my children.

I do not know the circumstances surrounding the "diagnosis" or "verdict" of the relatively minor mark on my daughters cheek, however, knowing the cause for the mark and as a good loving mother I was traumatized by the sudden turn of events. I feel the procedures and techniques used by CAS to secure custody over my children have been flawed and caused misconception for all parties involved. Additionally, information and input by health professionals have been accurate to the extent of the circumstances or cause for concern, not for the case at hand.

For example, If I had a bruise and went to a doctor and asked to get a confirmation it is a bruise I don't see any hesitation not to follow on such a request and confirm. If I were to challenge a doctor by requesting confirmation it is not a marker but a bruise, there must me procedures to determine that, a verbal approval or mere sight of the mark cannot disprove a claim it is marker.

My children have been taken away from me without any way for me to disprove their claim when there was still an opportunity to do so.

My questions to you as a Medical health professional is as follows.

A) Firstly I would like to know if there is a medical report on the case and observation, if yes, please send it at your earliest convenience, it would be greatly appreciated. If there is not a report, I would like to know of the reason for absence of report is due to the insignificance of the case, or perhaps CAS has specifically requested not to produce one, or if they have denied the opportunity to receive one verbally or by any manner.

B) Also, I would like to know if the CAS has provided all the necessary background information for review and consideration in regards to my daughter's mark, or did they simply ask you regarding the "bruise" to which https://mail.google.com/mail/u/2/?ui=2&ik=b875672a34&view=pt&search=sent&msg=14310250948b3207 2/4 1/28/2014 Gmail - Patient Diagnosis - Clarification naturally in the course of your work it would referred to as a "bruise" (Henceforth a "medically confirmed bruise"). Whereas in such an event the issue at hand is whether treatment is necessary or not, and obviously there was no reason for it.

C) According to my analyse, and correct me if I'm not right, there was not performed any tests to determine whether my knowledge of the mark to be permanent marker with my effort to remove the color, or whether the claim of the youth worker's claim that it is a bruise. I believe that you see no reason to perform any tests, so in order not to question I conclude that the CAS didn't give you the information that ultimately make such a test deemed necessary.

D) Without questioning your professionalism as an emergency medical profession, I'm wondering if the emergency courses at the university did in fact ever coming to this issue of determining between a mark from a permanent marker and a bruise. It sound to me a very rare and even unique situation that usually not involves an emergency room and its staff. Only if it was verified and proven it was bruise a doctor is required to determine the severity of the blow, medical treatment needed, etc.

E) I also would like to know your opinion on this question. If in the future a case where there is a dispute to the nature of a mark to a child and there there is no danger or need for treatment, and the two claims are reasonable (as was the case with my daughter) if a doctor is the first method to determine the facts and disprove a parties claim, since I believe that a preliminary test to determine whether a mark is a marker or a bruise can be done even before visiting a doctor. A simple procedure such as applying a cotton swab with rubbing alcohol would suffice. If the texture or color of the mark lessens or changes however slightly, it is obviously marker and not a bruise. If there was no test performed, I believe there you see no reason for a test to be done, as background information was lacking. My conclusion again that it was referred to as a bruise in the context of the situation, individuals involved, and the seemingly insignificance of the matter. Were the matter presented correctly It would have changed the scenario and the truth would have been revealed.

F) If you would have known the backdrop to the visit by CAS to the emergency room and the grave consequences it involved, what test would you have performed to determine the truthfulness of the claim by myself that it was marker or the claim by CAS that it is a bruise and not a marker?

I have in my possession pictures of the mark given to me with all the court documents pertaining to the story with my daughter and son, they are now reunited with me and their father, my husband. Now that the mark is gone, I would like to bring the pictures to you to determine the accuracy of the claims and perhaps get a judgement by you to back one party, either me, the mother. or CAS. Please let me know if such a test can be done and if not, if you can please explain the reason it cannot be done.

Therefore I would like to know the circumstances surrounding the "confirmed bruise" whether it was in the context of determining the truth or in the context of medical attention needed or other perception of the need to confirm the circumstances and facts and not for the sake of investigation or the circumstances surrounding the visit.

I have cc'd my lawyer and I hereby declare my authorization for Dr. M. Newell to include my lawyer, Mr. Chris Knowles in all correspondence regarding this case.

I would appreciate your prompt written response to all the concerns addressed in this letter, and thank you in advance for doing so.

Miriam G Helbrans

Chatham, Ontario

Mailing address for correspondence:

222 St. Clair St. Unit 104 Chatham, Ontario N7L 3J4 https://mail.google.com/mail/u/2/?ui=2&ik=b875672a34&view=pt&search=sent&msg=14310250948b3207 3/4 1/28/2014 Gmail - Patient Diagnosis - Clarification Canada

https://mail.google.com/mail/u/2/?ui=2&ik=b875672a34&view=pt&search=sent&msg=14310250948b3207 4/4

THIS IS EXHIBIT "B" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014

THIS IS EXHIBIT "C" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014

THIS IS EXHIBIT "D" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 The following information are taken from: http://www.yakovrabkin.ca/ About the author

Yakov M. Rabkin is Professor of Contemporary History at the University of Montreal. He has also been a Visiting Scholar at several universities, including Yale, Johns Hopkins, Hebrew, Bar-Ilan, Tel Aviv, Université Louis-Pasteur and the Smithsonian Institution. He has received research awards from Belgium, Canada, France, Israel and the United States. He has studied Judaism at the Yeshivat Dvar Yerushalaim, the Pardes Institute, the Shalom Hartman Institute and the Bet Morasha Centre for Advanced Jewish Studies in Jerusalem, at the Centre Rachi in Paris as well as in private sessions with several rabbis. He was an Associate Member of the Jerusalem Center for Public Affairs for over a decade and collaborated with Rabbi Adin Steinsaltz of Jerusalem in reviving Jewish education in the former Soviet Union in the late 1980s. His most recent book is A Threat from Within: a Century of Jewish opposition to Zionism. Currently available in twelve languages, it has been nominated for Canada’s Governor-General Award, Israel’s Hecht Prize for Studies in Zionism and listed as one of the three best books of the year in Japan. His analyses of Jewish and Israeli issues have appeared in print in, inter alia, Baltimore Sun, Asahi Shimbun, France-Ouest, Frankfurter Allgemeine Zeitung, Cape Times, The Age, Jerusalem Post, Jewish Chronicle, Midstream, Haaretz, Le Devoir, Milenio de México, Noticias de Buenos Aires, Libre Belgiue, and L’Économiste. He has also appeared in major electronic media such as BBC, Radio France, Radio Canada TV, Radio Argentina, Irish Radio, CTV, and USA Radio Network. Professor Rabkin’s publications include Science between the Superpowers, a study of Soviet-American relations in science and technology (Priority Press, 1988), The Interaction of Scientific and Jewish Cultures in Modern Times (The Edwin Mellen Press, 1995), Diffusion of New Technologies in Post- Communist Europe (Kluwer, 1997), a major overview of science in pre-Revolutionary Russia that appeared in L’Europe des sciences (Seuil, 2001) and a comparative analysis on science in the Soviet Union and Nazi Germany in Science and Ideology (Routledge, 2003). He has also published nearly two hundred scholarly articles on the entry of Jews into modern science, on science and religion interface, on relations between science and cultures. His consulting experience in the field of science policy includes work for OECD, NATO, World Bank as well as for the government of Canada.

Married to Estela Sasson; they have children: Miriam, Meir, Guéula, Hinda and Moshe Hillel.

Address: Professor Yakov M Rabkin, Département d’histoire, Université de Montréal, CP 6128, Succursale Centre-ville, Montréal, Canada H3C 3J7 Telephone: (514) 343 7218; e-mail: [email protected].

EXPERT SUBMISSION BY PROFESSOR YAKOV RABKIN ______

I, undersigned, Yakov Rabkin, Canadian passport BA291904, residing at 6229 Chemin Deacon, Montreal, Qc, Canada, affirm that this statement (consisting of four pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have willfully stated anything in it, which I know to be false, or do not believe to be true. This is a preliminary submission in preparation for an oral testimony in the case 57722-09-11 to be heard before Judge Rivka Makeis at the Court of Family Affairs at Rishon Letsion, Israel.

Qualifications and experience

Professor Rabkin has taught contemporary Jewish history and the history of science at the University of Montreal since 1973. Full Professor at the Department of History since 1987, he recently developed and taught seminars on Islamic and Judaic attitudes to science and technology. He has served as a Visiting Scholar at several universities, including Yale, Johns Hopkins, Bar-Ilan, Hebrew and Tel Aviv universities, Université Louis-Pasteur and the Smithsonian Institution. He has also consulted major international organizations (such as NATO, OECD and World Bank) as well as Canadian government agencies.

Professor Rabkin has been invited to appear as expert witness before the Committee on Foreign Relations of the Parliament of Canada as well as before the Immigration and Refugee Board in Montreal and before the Crown Court in Leeds, Britain.

Professor Rabkin developed an interest in Jewish studies in the late 1970s. Besides university courses taken in Baltimore, Jerusalem and Montreal, he has also studied at the Jerusalem Academy of Jewish Studies, the Pardes Institute, the Shalom Hartman Institute and the Bet Morasha Centre for Advanced Jewish Studies in Jerusalem, at the Centre Rachi in Paris as well as in private sessions with several rabbis. He has published scholarly and general articles on Jewish and Israeli topics and has given lectures on Judaica and Jewish history in several countries. He assisted Rabbi Adin Steinsaltz of Jerusalem to open the first overt Jewish educational institution in Moscow in 1988. He was an Associate Member of the Jerusalem Center for Public Affairs for over a decade, and took part in the Canadian Academic Study Circle on Zionism. Professor Rabkin served as member of the Hillel Foundation Board of Directors, organized and headed the House of Jewish Knowledge and the Russian-Jewish Association affiliated with the YMHA in Montreal.

His publications include Science between the Superpowers, a study of Soviet-American relations in science and technology (Priority Press, 1988), The Interaction of Scientific and Jewish Cultures in Modern Times (The Edwin Mellen Press, 1995), Diffusion of New Technologies in Post-Communist Europe (Kluwer, 1997), a major overview of science in pre-Revolutionary Russia that appeared in L’Europe des sciences (Seuil, 2001) and a comparative analysis on science in the Soviet Union and Nazi Germany in Science and Ideology (Routledge, 2003).

Professor Rabkin’s most recent book is A Threat from Within: a Century of Jewish opposition to Zionism (Zedbooks/Fernwood, 2006; originally published in French in 2004). This book was nominated for the Governor General Award in Canada, for the Hecht Prize for Studies on Zionism in Israel, was listed as the best book in non- fiction in Japan’s leading daily Asahi Shimbun and received special distinction at the Rendez-vous de l'histoire in Blois, France. It is now available in thirteen languages. The Israeli publications Jerusalem Post, Haaretz and Kountrass devoted considerable attention to the book, with Haaretz running a week-long online interview with the author. A Hebrew version is due to appear in Israel in early 2012.

He has also published over a hundred scholarly articles on the entry of Jews into modern science, on science and religion interface, on relations between science and cultures. His analyses of Jewish and Israeli issues have been published in several countries, including in Tikkun, Jewish Chronicle, Baltimore Sun, Aqdamot and Jerusalem Post. He has also authored articles published in Canada, France, Israel and the United States addressing the issue of Jewish dissent and antisemitism.

Professor Rabkin is married and is the father of five children, ranging from 20 to 30 years old. Two of his children are university students, one is an investment consultant at a major Canadian bank, one daughter has received a master’s degree in international law and is currently an intern at the International Court of Arbitration in The Hague, and another daughter is a senior programme officer at Canada’s Ministry for Foreign Affairs and International Trade.

I have been asked to share my knowledge of the Lev Tahor community at Sainte-Agathe des Monts, Qc, Canada, specifically addressing the issues related to their treatment of minors and to the character of its members’ affiliation with the community.

My acquaintance with Lev Tahor began in 2003 in the course of my research on Jewish religious opposition to Zionism. I have since visited the community, situated a hundred kilometers to the north of Montreal, about forty times. My visits have had mostly to do with research, I have interviewed the community leader Rabbi Helbrans several times, have discussed education of children with his wife Malka, have videotaped several interviews with Lev Tahor members (both males and females), and occasionally, during summer months, would visit the community unannounced to attend afternoon services at their synagogue since it was only a few kilometers from the country house I rented at the time. I have also attended three or four weddings celebrated at the community, and stayed overnight with different families on a few occasions when I was too tired to drive home. I am also familiar with publications issued by Lev Tahor.

The children at Lev Tahor appear quite similar to their peers at other haredi communities. I have seen them study, play outside, tend vegetable gardens as well as in the family context. There is the usual gender segregation, with all females wearing black capes, which seem distinctive of Lev Tahor. The community receives regular visits from relevant government bodies in charge of education, and due to its location, is quite exposed to neighbours and passers-by. They maintain their religious and social isolation while situated in a rather busy part of the town of Sainte-Agathe- des-Monts.

The weddings I attended were rather public affairs with hundreds of guests from other haredi communities. Sometimes the newly wed were quite young, viz. about 16 or 17 years old, which is legal in, but certainly unusual for, Quebec, while this is quite common among strictly observant Jews.

As is usual in haredi communities, there is a good degree of mutual aid and solidarity. While the community is not wealthy, there exist appear to exist economic differences, with some families having better appointed homes and newer cars. All the children, however, appear normally fed and clad.

The videotaped interviews with Lev Tahor members indicate that the recruitment to the community happens mostly in Israel. Publications play the main role in attracting new members to what they consider a more authentic manner of living as Jews. Many point out at the search for truth as the root cause of their initial interest in Lev Tahor. Not all members stay in the community, even though the community experiences a moderate growth in spite of some outflow. One can see a lot of reverence expressed to the community leader (or Rebbe), which is quite similar to what I observed in other Hasidic groups.

THIS IS EXHIBIT "E" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 1/30/2014 Media Resource: Fearing children might be taken away, Anti-Zionist Hasidim flee Quebec - UdeMNouvelles Media Resource: Fearing children might be taken away, Anti-Zionist Hasidim flee Quebec MARDI, 10 DÉCEMBRE 2013 09:19 NEWS

For ten years, University of Montreal Professor Yakov Rabkin has been studying the Hasidic anti-Zionist group Lev Tahor. The group fled Quebec on November 19 in order to avoid a youth court hearing to have children removed from their families.

The Toronto Star reported on Dec 8 2013: “On November 27, a Quebec youth court judge gave the order to seize the children, who range in age from 2 months to 16 years. The judge ruled there was a ‘serious risk of harm' to the children. To date, the order has not been carried out by the Chatham-Kent Credit: The Windsor Star Children's Aid Society.”

The following Q&A is free of copyright and has been prepared to assist the media. Journalists are welcome to use the provided questions and answers in part or in whole. For interviews and further information (including the original French text of this document,) please contact media relations at the University of Montreal ([email protected]). The University of Montreal is officially known as Université de Montréal (www.umontreal.ca).

Further information about Professor Yakov Rabkin and his expertise is available at www.yakovrabkin.ca

Question: How are Lev Tahor members different from other Hasidic Jews?

Y.R.: The main difference is that they almost all grew up in an irreligious environment. It was not until adulthood that they drew closer to Judaism and began practicing religion. While most of Lev Tahor children were born in Quebec, the majority of adult members, about 50 persons, came from Israel where they had been raised with the ideology of Zionism. Some are former officers of the Israeli army who embraced Hasidic Judaism, left the army, and then the State of Israel. Lev Tahor stands out by its unusually strict practice of Judaic law regarding food, clothing, and prayer.

Question: Are the children in danger?

Y.R.: I don't know whether or not there has been abuse, but the times I went to visit the community, sometimes without notice, I didn't see any violence. The boys appeared similar to other Hasidic boys. However, in recent years, the girls and women started to wear veils and came to look different from women in other Hasidic communities

A few years ago in the framework of a film project, I videotaped interviews with several members of the community, both men and women –unveiled- about their background and their motivations to join Lev Tahor, but I didn't talk with the children.

To avoid controls stipulated in the Quebec Public Education Act, they began planning a move to Ontario several months ago. They spoke to me about this when I visited them last summer with a PhD student in anthropology from Brazil.

Question: Some argue that members of Lev Tahor are backward. Are they?

Y.R.: Their opposition to Zionism led them to learn Yiddish, spoken by Hasidic Jews, so they would no http://www.nouvelles.umontreal.ca/udem-news/news/20131210-media-resource-fearing-children-might-be-taken-away-anti-zionist-hasidim-flee-quebec/impr… 1/2 1/30/2014 Media Resource: Fearing children might be taken away, Anti-Zionist Hasidim flee Quebec - UdeMNouvelles longer use modern Hebrew, even though it is the mother tongue for most of them. They deliberately reversed the Zionist project, the efforts Zionist pioneers made more than a century ago when they abandoned Russia, their homeland, and settled in Palestine. They also rejected Yiddish, their mother tongue, and desacralized Hebrew, the language of prayer and Torah study, turning it into a vernacular.

While some consider Hasidic Jews ignorant of the modern world, members of Lev Tahor used to be immersed in secular Israeli society. This is why their rejection of Zionism is more of a provocation than that of other Hasidic Jews, who have inherited anti-Zionism, along with other values, from their ancestors.

Not surprisingly, Zionists in Israel and elsewhere are very upset with Lev Tahor. In a television report, an Israeli parliamentarian accused them of wanting to kill all nonbelievers in Israel. A reporter from Haaretz, a daily often considered to be anti-religious, spent a few days among the Lev Tahor. His informative articles are available online [www.haaretz.com/weekend/magazine/lev-tahor-pure-as-the-driven-snow-or-hearts-of- darkness-1.417553].

Question: How do you explain the attention given to Lev Tahor?

Y.R.: I understand the antagonism Lev Tahor generates in Israel. The relatives of those who joined Lev Tahor are almost all secular Zionists. They are horrified by the new lifestyle of their children and by the education given to their grandchildren. Based on the testimonies of those who rebelled against Lev Tahor, including a son of the group's leader, Rabbi Shlomo Helbrans, these relatives alleged child abuse. They protested outside the Canadian Embassy in Tel Aviv and mobilized Israeli authorities, which put pressure on child protection agencies in Canada.

Hence the recent attention of the Quebec Directorate of Youth Protection to the Hasidim of Sainte-Agathe. For several months children were checked for signs of beatings, and homes, including refrigerators, were inspected almost daily. Last week, Lev Tahor was discussed by an Israeli parliamentary commission for the protection of children. So far the testimony before the commission came from critics of this Hasidic group. I suppose Lev Tahor members will be heard in the future even though the commission must have many other priorities: in Israel, one in four children lives below the poverty line.

Media contact: William Raillant-Clark International Press Attaché University of Montreal (officially Université de Montréal) Tel: 514-343-7593 [email protected] @uMontreal_News

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THIS IS EXHIBIT "F" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 1/30/2014 NAICU - 2013 Paley Award Citation: Bernard Fryshman, Executive Vice President, Association of Advanced Rabbinical and Talmudic Schools

2013 Paley Award Citation: Bernard Fryshman, Executive Vice President, Association of Advanced Rabbinical and Talmudic Schools

Dr. Bernard Fryshman never wanted this honor. As a matter of fact, when contacted that he had been selected, he spent several days reflecting on whether he should accept. Had it not been for the persuasive talents of his family - the only ones we have ever seen change Bernie's mind about anything - he would not have been here to accept this award.But those same personal traits - humility, honesty, and a sense of purpose larger than one's self - are the reasons Bernie has been such an effective, lifelong advocate for independent higher education. The passion and commitment Bernie has brought to his work has always been about the greater good. It is a passion founded on a belief in human dignity, the importance of the mind, and the welfare of students. It is also a passion anchored in faith, and in the Talmudic tradition of careful analysis and thought.

Bernie has been a continuous presence on Capitol Hill. He quietly walks the halls, typically with a lengthy paper in hand, patiently engaging impatient young staff members in an intellectual dialogue about legislative intent and consequences. He is always the teacher, pursuing dispassionate thought in a volatile - and not always thoughtful - political environment.

Born in Montreal, Bernie came to the United States, and to New York City, to earn his Ph.D. in physics at New York University. In all the decades that followed, he never left the field of physics. The Spring 2013 semester will mark 50 uninterrupted years of his teaching the subject - presently at the New York Institute of Technology. (On a five-point scale, he=s rated 4.3 on RateMyProfessor.com, with effusive student comments about his ability to lucidly teach physics principles without use of a textbook.)

Throughout his career, he has bridged two worlds: that of his faith, and that of his profession. The two worlds may be most perfectly aligned in his leadership of the Association of Advanced Rabbinical and Talmudic Schools, which he has headed since 1973, and in his long-term commitment to making what happens within those schools accessible to the outside world.

At the same time, in a parallel universe, Bernie has devoted these past 40 years to extraordinary service to the broader world of higher education nationally. Since 1973, Bernie has been a driving force in higher education accreditation. He served two terms on the predecessor to the National Advisory Committee on Institutional Quality and Integrity, the body that advises the U.S. Department of Education on issues related to higher education accreditation and institutional eligibility for federal student aid programs. He also has served on committees of the Council for Higher Education Accreditation and the Association of Specialized and Professional Accreditors.

A prolific writer, especially on issues relating to accreditation, Bernie=s opinion pieces have often appeared in Inside Higher Ed and other publications, and have been an important force in shaping the national higher education policy conversation.

Within NAICU, Bernie=s service has been long-term and influential, including testifying on behalf of the association before congressional committees, and service on NAICU board committees. A member of NAICU=s Secretariat, composed of nearly 30 special-focus private college associations, he first became part of the group in 1976, and notes AThere are several generations of people who consider me a thorough pest.@

When asked to sum up what he felt had been his most important contribution over a long and illustrious career, he simply says, ABeing able to serve the cause of education in general, and rabbinical and Talmudic education in particular.@

It is in recognition of his success in achieving that simply-stated mission that he has been chosen to receive this award. For his remarkable accomplishments and steadfast commitment as a master craftsman in both the art and the mechanics of higher education, the National Association of Independent Colleges and Universities is honored to present its 2013 Henry Paley Memorial Award to Dr. Bernard Fryshman.

Named for Henry Paley, president of the Commission on Independent Colleges and Universities of New York from

http://www.naicu.edu/printVersion/print_default.asp?sectionID=13&ID=1619&iPage=1&type=0 1/2 1/30/2014 NAICU - 2013 Paley Award Citation: Bernard Fryshman, Executive Vice President, Association of Advanced Rabbinical and Talmudic Schools 1975 until 1984, the award recognizes an individual who embodies his spirit of unfailing service toward the students and faculty of independent higher education. The winner of this award has set an example for all who would seek to advance educational opportunity in the United States.

Award Winners – Henry Paley Memorial Award

1985 Rev. Timothy S. Healy, Georgetown University 1986 James Ream, Pennsylvania Association of Colleges and Universities 1987 Frank "Sandy" Tredinnick, Association of Independent Colleges and Universities in Massachusetts 1988 The Honorable William H. Natcher, U.S. House of Representatives 1989 The Honorable Thomas H. Kean, Governor, New Jersey 1990 The Honorable Silvio Conte, U.S. House of Representatives 1991 Francis "Mike" Michelini, Association of Independent Colleges and Universities of Pennsylvania 1992 (Special Summit Meeting – no award was given) 1993 Derek Bok, Harvard University 1994 Sr. Dorothy Ann Kelly, College of New Rochelle 1995 Richard F. Rosser, National Association of Independent Colleges and Universities 1996 John Frazer, Association of Independent Kentucky Colleges and Universities 1997 James Whalen, Ithaca College 1998 Rev. William J. Sullivan, Seattle University 1999 David Irwin, Washington Association of Independent Colleges and Universities 2000 Sr. Mary Andrew Matesich, Ohio Dominican College 2001 (Special NAICU 25th Anniversary Meeting recognizing all previous recipients – no new award was given) 2002 Allen P. Splete, Council of Independent Colleges 2003 James C. Ross, Commission on Independent Colleges and Universities of New York 2004 Michael S. McPherson, Spencer Foundation, Macalester College 2005 Robert N. Kelly, Kansas Independent College Association 2006 Clare Cotton, The Association of Independent Colleges and Universities of Massachusetts 2007 Alexander W. (Sandy) Astin, Higher Education Research Institute, University of California 2008 The Rev. Theodore M. Hesburgh, C.S.C., University of Notre Dame 2009 Morgan Odell, Association of Independent California Colleges and Universities 2010 Sister Kathleen Ross, snjm, Heritage University 2011 The Rev. Charles L. Currie, S.J., President, Association of Jesuit Colleges and Universities 2012 Patricia A. McGuire, President, Trinity Washington University

This information was found online at: http://www.naicu.edu/events/page/2013-paley-award-citation-bernard-fryshman-executive-vice-president- association-of-advanced-rabbinical-and-talmudic-schools

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We Are All Lev Tahor Bernard Fryshman Ph.D. January 27, 2014

One can’t really blame the Quebec Provincial Government. Terrified by the possibility of a homegrown Islamist movement, legislators are viewing all extremist movements with suspicion. Philippe Couillard, the recently appointed leader of the Quebec Liberal party expressed it clearly in conjunction with a bill to ban public servants from wearing religious garb and symbols: Religious fundamentalists and extremists “are not welcome in Quebec” he said, (quoted in the 12/18/13 Globe and Mail), proposing “concrete actions.” The report added that Couillard said ‘groups such as the Lev Tahor Jewish orthodox sect, which has come under investigation by child welfare authorities in Ontario and Quebec for child neglect, threaten “social destruction”’. Lev Tahor also merited special mention in the 12/18/13 article in the Montreal Gazette, to quote: “As an example of unacceptable behavior, Couillard referred to Lev Tahor, the extremist Jewish sect whose members are alleged to have abused their children.” And so we have it. Religious fundamentalism and extremism have been conflated in the words of the man who could be Quebec’s next Premier, and Lev Tahor has been labeled as guilty of child neglect and child abuse. A nice neat package, except for the fact that to one extent or other, all faiths which base their beliefs on sacred works fall somewhere along the fundamentalist spectrum. It’s easy to marginalize Lev Tahor: their culture emulates a lifestyle characteristic of European Jewry 150 years ago. But their religious practices and social mores fall squarely within Orthodox Jewry. To a non-Jewish secularly-minded Quebec citizen, many Chassidic groups would similarly fall in the ‘fundamentalist’ spectrum. Suddenly, a 200 year history of a Jewish presence in Montreal – a history of a loyal, peaceful group which contributed so much to the growth, commerce and culture of this city is in jeopardy. Because so many Jews fall somewhere in the fundamentalist range, and because fundamentalism and extremism are viewed in the same light, they could become as unwelcome as Lev Tahor. Perhaps more troubling is the fact that Lev Tahor has been accused of child neglect and child abuse, without a shred of evidence to support either contention. This, in spite of the fact that Quebec’s child protection apparatus has maintained a microscopic, vigilant eye on the community, without a single confirmed finding. The same, by the way is true in Ontario. Accusations and malicious rumors persist, but no findings of neglect and no findings of abuse. As noted above, one cannot blame Quebec’s legislators. There is fear and there is concern.

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One must, however, speak out against the silence. There is silence from the Fourth Estate. Evidently some Canadian journalists view their role as presenting, in a pleasant readable fashion, the information presented to it. Forgotten is the role of the editorial writer, to gently (at first) remind the leader of Quebec’s Liberal party of the difference between fundamentalism and (presumably, violent) extremism. Forgotten, too, with a few exceptions, is the role of the investigative reporter who can ascertain whether or not there was any neglect or abuse of Lev Tahor children. Small minority communities have a right to expect that the Press will protect their freedom from an overbearing government, no matter how well intentioned. Andthere is the strange silence from citizens who care about civil liberties. For some, the fact that Lev Tahor has been labeled a cult is ample justification for silence and inaction. They do not seem to realize that the reason for the capricious actions by Quebec authorities is that Lev Tahor is viewed as a fundamentalist sect. They forget that other groups, too, can be viewed by the general population as fundamentalist sects. In this regard, the effort by the Centre Jeunesse des Laurentides Youth Protection division to have fourteen Lev Tahor children taken from their Chatham, Ontario homes and placed in Quebec foster homes is instructive. On November 14, 2013 a petition was filed in Quebec Court outlining the reasons “the security or development of the children are considered to be compromised.” The entire list of findings submitted to the Court are included at the end of this article. Readers will judge the implications for themselves, but a few findings merit comment: 3.3) The legitimacy of the community “Lev Tahor” is not recognized by other Orthodox; Jewish communities This signals a new area of concern for all religious bodies. If the legitimacy of a religious community is to be predicted by its ‘recognition’ by another group or groups, then all religious bodies are threatened. 3.4) The children are not in school; 3.10) The boys attend, several hours a day, a place where religious education is given to them;

These mutually contradictory findings (along with findings 3.5, 3.6, 3.7, 3.8, 3.14) suggest that the reason the children are to be taken from their families is because of the nature of their education rather than because of abuse or neglect. This, by the way, is the reason the Mennonites also fled the Province of Quebec. 3.13) Children react negatively by fear, distrust and disgust when put in contact with external people to the community and their way of life;

Compare this claim with the observation by Canadian Jewish News reporter Paul Lungen who, unlike most other journalists, took the trouble to explore the Lev Tahor community first hand and in depth. Writing in the January 20, 2014 edition of the newspaper, Lungen observes:

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In a 2-1/2-hour visit earlier this month to the Lev Tahor shtetl, located on the outskirts of Chatham, I found dozens of smiling children, curious about the newcomer and eager to have their photos taken. Boys were in school, studying Judaic subjects. Boys and girls are educated separately. 3.17) Most of the girls in the community suffer from fungal infections in the feet, directly in connection with the obligation to wear stockings, days and nights;

Now read this report by Assistant Professor (McGill University) of Dermatology, Rachel Rubinstein, MD, FRCPC: My name is Rachel Rubinstein, MD, FRCPC, and am assistant professor of dermatology at McGill University and practice out of the Jewish General Hospital in Montreal. I was asked to visit the Lev Tahor community in St. Agathe, Quebec on November 14, 2013 to evaluate and treat their dermatologic problems. In general, I found the children to be clean, well- cared for and behaving appropriately. I was impressed by the warmth of the community and concern of the parents for the well-being of their children. Overall, I evaluated 61 patients, the majority of which were children, at the Lev Tahor community. The most common problems I encountered were onychomycosis (nail fungus), stopic dermatitis, acne and warts. These are typical clinical problems I routinely encounter in my dermatologic practice. These are relatively benign conditions, many of which spontaneously resolve in early adulthood. It is important that I emphasize, unequivocally, that these problems do not reflect parental neglect or abuse. As such, there is absolutely no indication for intervention by child welfare authorities regarding these minor skin conditions. The other findings need no further comment: every person of faith will find good reason to object to a government agency interpreting religious practices as justifying placing a child in foster care. Foster care for abused children is a necessity; taking a child which is in a caring relationship from its mother is traumatic. Reportedly many children so removed never recover and remain troubled for life. Fourteen Lev Tahor children are threatened with this draconian edict, for reasons of their culture and faith – and for no other reason. Silence in the face of such overbearing insults to the civil liberties of Lev Tahor is taken to mean acquiescence. If authorities can use unfounded accusations of neglect and abuse to move these fourteen children into foster homes, whose children will be safe? Lev Tahor is the canary in the coalmine. Small, vulnerable, weak and inoffensive. We ignore its fate at our peril.

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Findings presented to the Court of Quebec,Youth Division #700-41-009405-134

3 –The security or development of the child are considered to be compromised in that:

3.1) The family lives under the influence of the community “Lev Tahor”, headed by Rabbi Schlomo Helbrans; 3.2) Children are isolated from the outside world at the community “Lev Tahor”; 3.3) The legitimacy of the community “Lev Tahor” is not recognized by other Orthodox Jewish communities. 3.4) The children are not in school; 3.5) Children know neither read nor write the French or English; 3.6) The children speak only Yiddish except Yehodit Nechama and Miriam who have minimal English; knowledge 3.7) Children are not general knowledge corresponding to their age; 3.8) Children have access to any book or materials; 3.9) Girls occupy their days for the maintenance of the home, to cook and to pray; 3.10) The boys attend, several hours a day, a place where religious education is given to them; 3.11) Children do not have access to other games or toys; 3.12) Children play out; 3.13) Children react negatively by fear, distrust and disgust when put in contact with external people to the community and their way of life; 3.14) Parents neglect education and stimulation of the child; 3.15) At the age of three, girls are dressed with a chador, a garment which leaves show as the oval of the face; 3.16) The dress code for girls in the community is very strict; 3.17) Most of the girls in the community suffer from fungal infections in the feet, directly in connection with the obligation to wear stockings, days and nights; 3.18) The child is subjected to a power imposed on the community “Lev Tahor”; 3.19) It is usual that the girls in the community marry at the age of fourteen (14) years; 3.20) Rabbi Helbrans and groom parents arranged the marriage; 3.21) At the ceremony of the marriage, the spouses see themselves for the first time; 3.22) The marriage is formalized through a sexual relationship which must have following the ceremony and before the sunrise; 3.23) The sexual relationship must be confirmed by a Rabbi of the community, Aaron Teller, responsible for this task; 3.24) Four years ago, parents have lost a baby died of SIDS infant; 3.25) Children can be removed from their families in order to punish the parents of behaviour not the rules of the community; 3.26) Children are at risk of going to hell if they disobey the rules of the community; 3.27) The children take tablets of melatonin several times per day; 3.28) The security and development of children are compromised by educational, school, dropping negligent psychological abuse and risk of abuse for Yehodit Nechama and Miriam;

Verbatim from translation of court papers.

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THIS IS EXHIBIT "G" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014

Reaction to Testimony of Adam Brudzevski Regarding Lev Tahor

Bernard Fryshman, PhD. December 17, 2013

December 17, 2013

To many New Yorkers, the name ‘ Rabbi Helbrans’ brings to mind a criminal trial about fifteen years ago in which he was sentenced to a two year prison sentence for an action which has yet to be established as illegal, or even wrong.

Many people tried to help the Rabbi, but others observed the proceedings with equanimity, consciences clear because he was reputed to be the head of a cult.

‘Cult’ is also the reason given by many people in Montreal who quietly watched as Rabbi Helbrans’ community in nearby St. Agathe was harassed by Quebec authorities to the point that all 35 families fled to the province of Ontario.

On November 27, 2013 Court hearings (Cour du Quebec, Chambre de la jeunesse) took place with testimony by Adam Brudzevski who left the community in the fall of 2011.

The provincial authorities were certain that Brudzevski’s testimony would establish that Lev Tahor (as Rabbi Helbrans’ community is called) is abusing children and the entire movement is a cult. Only it didn’t quite turn out that way…

Adam Brudzevski was born to two Danish Jews who separated many years ago. Adam lived a good part of his life in India, with his father.

About eight years ago he was an intimate part of the San Francisco hippie scene, living there for a number of years. His next life began with an encounter with Rabbi Tropper, the head of Kol Yaakov, a Rabbinical Seminary (now closed) located in Monsey, New York.

While studying at the school Brudzevski became close to some Lev Tahor people, concluded that the people in Monsey weren’t properly observant, and joined the Lev Tahor move from Monsey to St. Agathe in the fall of 2009.

He fit in perfectly - dress and all, and a half year later married the daughter of a prominent member of Lev Tahor. Two years later, in 2011, he and his wife left the community and for a time went to live in Denmark.

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The sworn testimony was highly revealing. First and foremost it confirmed that Lev Tahor is not a cult. People come and people go; the community lives in the middle of an urban setting, and there are members who have access to the Internet. There is no question that Rabbi Helbrans is a charismatic leader, but any indoctrination that takes place is squarely within the bounds of Halacha. The fact that the societal overlay is that of a Jewish community 200 years ago doesn’t make the community a cult, and while people may want to designate it as such, they forget that their Judaism and their own Orthodoxy is fully cult-like to someone from the broader culture looking in.

Also of interest is the fact that after all the accusations, the complaints to provincial authorities, the reports of child abuse, and the countless visits and investigations carried out in St. Agathe, the Province had to rely on Adam Brudzevski, a young man with an uneven, if not troubled past, as the basis of its presentation to the Youth Commission. In his own words,

18 IQ. How long did you spend in the community Lev Tahor? 19 A. So I stayed for one week at the time. I came back.. 20 and came back a couple of months later and stayed 21 for … initially for three weeks. 22 IA. Donc, initialement, je suis resté pour une semaine. 23 Quelques semaines plus tard, j’y suis retourné puis 24 je suis resté pour une période de trois semaines. 25 A. That… and I didn’t follow my plan, and I ended up (p.4) staying in the community, and I stayed for almost two years. Following his own pattern,

16 A. As I stayed in the community, I started having more 17 and more questions about the, about the righteousness 18 of what was going on. (p.5)

2

A young man, then 26 years old, who lived in Denmark, ran with his father to India, lived a hedonistic life in San Francisco, then jumped to Orthodox Jewry and Kol Yaakov - which soon also failed to meet his standards, is now making judgments, about a community which welcomed him to its fold.

17 IQ. Why did you decide to denounce what you actually 18 experienced in the community? Why did you actually 19 tell the social workers and the police? 20 A. Because I have a belief that I’m obligated to help 21 and … Jewish children that are in trouble, Jews that 22 are in trouble. 23 IA. Parce que je crois que je suis dans l’obligation 24 d’aider des enfants juifs qui ont des problémes. 25 A. And I believe that the conditions that the people are (p.77) 1 living under in the community are damaging to them. 2 IA. Et je pense que les conditions dans lesquelles ils 3 vivent dans la communauté leur font du tort, leur 4 causent du tort. 5 A. And I have grounds for that by seeing how members who 6 left the community are unable to live a normal life. (p.78) 15 A. Personally, I believe that a person should have a 16 free choice and decision how to live his life.

It evidently never dawned on Mr. Brudzevski that the people of Lev Tahor also believe in free choice, and don’t need him to ‘denounce’ them and tell them how to live…

It’s noteworthy that Province of Quebec authorities could not bring a single example of drugs or crime associated with the young people of Lev Tahor. They were trying to build a case against the community, and they were reduced to grasping at straws.

Consider the complaint Brudzevski had that

3 A. Also, I had to subject myself to treatment for what 4 they called “borderline personality disorder” (p.8)

3

The symptoms of this disorder, he was told,

8 A. And the main point of… that they were bringing out 9 was saying that I had this disorder, was that I would 10 observe positive things and interpret it in a 11 negative way.

The Court feigned interest in his complaint:

7 IQ. Was there therapy, a treatment or a medication that 8 you had to undergo? 9 A. I, I didn’t get any medication. How… I was told 10 that if I would keep a healthy diet and eat my 11 vitamins, I wouldn’t need medication necessarily. (p.10)

The witness, alone, did not realize that he was being treated very gently by Lev Tahor, and that people were genuinely trying to help him.

5 IQ. So you said that you had to follow a diet and also to 6 take vitamins. Describe what kind of diet and 7 what sort of vitamin did you have to take. 8 A. Diet would be more or less what’s called the Atkins 9 Diet. 10 IA. Donc, au niveau de la diéte, c’était plus ou moins ce 11 qu’on intitule la diéte Hatkins. 12 A. And vitamins would be regular dietary supplements, 13 multivitamins. (p.12)

After this strange report, the Province persisted in seeking flaws:

20 IQ. Give us examples that brought you to question 21 yourself as far as what was going on in the Lev Tohar 22 community. 23 A. The first things I noticed… 24 IA. La premiére chose que j’ai remarquée…

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25 … was that the people were not abiding by the rules (p.13) 1 of the community. 2 IA. … c’est que les gens ne respectaient pas les réles 3 établies par la communauté. 4 A. And they didn’t, they didn’t show up on time what 5 they needed to be. 6 IA. Ils ne se présentaient pas à l’heure. Ils n’étainent 7 pas ponctuels par rapport, par rapport à des rendez- 8 vous. Pas ponctuels. 9 A. And being that I was together with the unmarried 10 boys, I especially noticed their lack of obedience. (p.14)

Did Mr. Brudzevski truly believe that the fact that people “didn’t show up on time” and that boys had a “lack of obedience” is indicative of something wrong with the community? We will never know.

One will also never know whether he took seriously the preposterous advice by Chaim Azaria Alter that Brudzevski control boys in his charge by hitting them “with a wire hanger” (p.15) or “slap them in the face with an open hand” (p.17). He noted that

16 A. For example, every classroom in the small boys’ 17 school… 18 IA. Par ecample, dans chaque classe des plus jeunes 19 garcons… 20 A. … would be equipped with a wooden stick or rod to 21 hit the children with. (p.16)

Whatever the case, Brudzevski as a substitute remembers hitting “three individuals” (p.18), obviously not to great harm or bad feeling:

17 A. And it happened to me several times that boys from 18 the school came to me and asked me to be their 19 teacher.(p.25)

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We will put aside testimony regarding the nature of the educational program, the emphasis on young people marrying before the age of 16, the anti-Zionism of the community, or the fact that everyone speaks Yiddish. After all, an excellent case can be made for the intellectual and critical thinking outcomes of Lev Tohar’s educational activities. The issues relating to freedom of religion did not belong before this Court. Government has no business interfering in the free exercise of religion, and the Province of Quebec is extremely sensitive to this.

Rather we will address the questions of threats and punishment in Lev Tohar, again in Adam’s own words.

21 IQ. What other methods were used as punishment when 22 somebody breached the rules? 23 A. If somebody would come late for the morning 24 prayers … 25 IA. Si quelqu’un se présentait en retard aux priéres (p.33) 1 matinales… 2 A. … they would be punished monetarily… 3 IA. Donc, il y avait des punitions monétaires… (p.34) 4 A. … according to how late they were. And…

5 A. And, but there always… were an explanation with a 6 reason. It’s not a punishment, it’s a help. (p.35)

This is not the way most of us would want to live, but certainly there are no fearsome punishments taking place.

A number of other community sanctions were detailed - all unusual, but nothing physical, and all were well within the structure of the community:

20 IQ. During the period that you were living in the 21 community, did your wife, did she get any sort of 22 punishment for any type of misbehavior? (p.45)

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After describing the ‘infraction’, the witness related:

12 A. And my wife was informed of two punishments. 13 IA. Donc, on a avisé ma femme qu’elle subira deux 14 punitions. 15 A. One was that she was not allowed to go to her 16 parents’ house for a week and a half. 17 IA. L’une était qu’elle était interdite d’accés dans la 18 résidance de ses parents pendant une semaine et 19 demie. 20 A. And the other punishment was that she was not allowed 21 to use her sisters as messengers. (p.47)

Adding,

5 A. Also… not phrased as a punishment, but maybe as a 6 guidance… (p.50)

Strange, unusual, but certainly not cruel or physical. Certainly, not the kind of atmosphere one finds in a cult.

One more example:

13 IQ. What are the threats of punishments that are invoked 14 by Rabbi Helbrans as far as people who wish to 15 leave the community? 16 A. Oh, I can give you some examples of it. 17 IA. Je peux vous en donner des examples. 18 A. When I considered leaving, he warned me what would 19 happen in afterlife to me. (p.79)

There is no doubt that there is much about the community which is displeasing and discordant to the 21st Century ear. But this is precisely the point. Lev Tohar is a community of Jews that has elected to emulate an approach to life which is characteristic of the 18th century in certain respects. There is not a shred of evidence of any physical mistreatment of adults - or abuse of

7 children. The community obeys the laws of the Torah - and respects and obeys the laws of Canada. In the end, that’s all that should concern us.

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THIS IS EXHIBIT "H" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 January 30, 2014 To the Honorable court,

RE: Ontario court of Justice, File Number 267/13, CKCS V. Helbrants & Laver.

I apologize for sending this letter by e-mail, but the urgency of the situation demands it.

Now that the much of the testimony regarding Lev Tahor has been released to the media, my wife and I wish to offer our knowledge of its primary accuser, Mr. Brudzevsky. I would like to make it clear that writing this letter brings us no joy, but that we feel compelled to tell what we know in the hope that the Honorable court's desire for truth judgment will bring to cast the investigative gaze to the individual behind the pointing finger, and finally shed light on a terrible affair.

To introduce myself: Although recently retired, I was a psychometrician in the area of testing and measurements for New York State for nearly 40 years. My wife and I are not members of Lev Tahor, but we are well acquainted with, and support the group. My daughter and her family have been members for 20 years, and we have visited them on many occasions, both planned and spontaneous. And while I can't testify to what is happening behind every door, I can say without reservation that we have never seen evidence of the horrible libels that have become so pervasive. More importantly, we are Mr. Brudzevsky's wife's grandparents, and through that relationship gained an intimate understanding of Mr. Brudzevsky, and of the troubled childhood that compelled him to viciously turn not only his own parents-in-law, but on the community that tried to help him, as well. Mr. Brudzevsky was once a member of MENSA. And as he confided to me, “Everything I learn sticks.” His mother told us that while still in Denmark he insisted on finding a wife who wanted to go in the “old-fashioned way, and dresses in black.” That search lead him, via India, Haight-Asbury, and many stops in between, to Lev Tahor. There, his superior intelligence facilitated his ability to assume any persona he chose, and in short order he fit right in and excelled. Once he achieved his goal, our grand-daughter, he turned against the community that befriended him, and his duplicity was revealed. Please understand that this is not mere conjecture. While living in Monsey, NY, Mr. Brudzevsky told me that he went to Lev Tahor to find a wife and then to leave. This was confirmed by his mother. There was never an intention to embrace the life practiced in Chatham, but to use that unsuspecting community. According to news reports, Mr. Brudzevsky indicated that he read the definition of a cult, determined that Lev Tahor was a cult, and that that “revelation” guided his subsequent actions. He claims that he had to effect his “escape” by surreptitiously smuggling in a laptop. This is untrue. Even before his marriage, my son-in-law told me that Mr. Brudzevsky had a web-based business, and that I could contact him by e-mail. Additionally, there was simply no need to plan an elaborate escape, after all, from an open, residential neighborhood from which the member of Lev Tahor travelled daily without impediments or restrictions. His personal restrictions grew from the fantasy developing in his mind, and dominating his thoughts.

1

From Lev Tahor, Mr. Brudzevsky and his wife went to Denmark, where his his mother, a clinical psychologist, revealed that he needed her professional help. She supported the young couple and their newly born son, while trying to entice them into self-sufficiency. Her efforts failed, and soon the Brudzevsky family was on its way to the US.

From Denmark they came to our town of Kiryas Joel. An insight into Mr. Brudzevsky's psychological difficulties emerge when one views his difficulty providing for his family. I have a daughter living nearby, and the Brudzevskys planted themselves in her basement, quite content to let my daughter care for their infant, as well as clothe, feed and shelter them. We were witness to this. In desperation, my daughter's husband found them an apartment in Monsey, NY. for which Mr. Brudzevsky's mother paid the rent. Periodically, she would call my son, who lived nearby, to motivate her son from his indolence. Curiously, Mr Brudzevsky's mother once flew from Denmark to visit him in Monsey, but ended up staying at my son's house, because, “I couldn't stand it anymore.”

Interestingly, Mr. Brudzevsky began attending a well-respected school in Monsey, NY designed for married men, and after a brief period he told me that that school, too, was becoming a cult, and thus he could no longer attend. It became obvious to both my wife and I that this young man displayed some significant psychological problems, but we kept silent.

Mr. Brudzevsky eventually found his “calling” in trying to destroy both Lev Tahor and his parents-in-law's hearts. They traveled to Quebec to testify at a court hearing, and found themselves unable to return to the US because he lacked the proper documentation, documentation that we, my son and my daughter offered to help him attain. In fact, there was a community organization not far from their home, providing that service without charge. The process is simple, painless and speedy, but he never bothered.

They returned to Montreal where they lived (and perhaps continue to live) on his mother's largess and the charity of others. In fact, the owner of the apartment actually called my son requesting the rent, because he was not being paid. Furthermore, as last I heard, they were receiving help from support groups assisting their daily functions, since they are unable to cope without supervision. His own mother, too, called my son repeatedly from Denmark, pleading for him to intervene in her son's ennui. Please note that my son has no relation with the Brudzevskys, and wants nothing to do with them.

And ennui is not too strong a word. When Adam Brudzevsky's wife was born, my mother provided her with a trust fund maturing on her 18th birthday. I gave all the information to Mr. Brudzevsky, but the funds have yet to be accessed, despite the fact that the trust having ended, is now encumbered by custodial fees. I did all the work, and redemption requires only a telephone call. Yet, there is no interest evinced in acquiring this “free” money.

One need not be trained in critical thinking to uncover the inconsistencies in Mr. Brudzevsky's testimony in the Quebec hearing. He claims that Lev Tahor is a cult totally subservient to the dictates of Rabbi Helbrans, yet he became disillusioned because nobody kept the rules. I have know members of true cults, such as the Moonies and the Children of God. Trust me,

2 they mindlessly hew to an uncompromising set of rules without the slightest deviation.

He claims that students suffered under corporal punishment, yet admits he was removed as a teacher because the students complained that he administered corporal punishment. He claims members were fined for not attending religious services, but that the fine would be rescinded for even the weakest excuse. There is no need to recite every inconsistency in order for the veracity of the witness to be suspect.

Lastly, much has been made of the use of the purported sleep aid, melatonin. I don't condone the use of supplements for children, but they are legal and widely advertised for children. I can understand, therefore, its use. Significantly, melatonin was introduced to Lev Tahor at Mr. Brudzevsky's wedding, by his own father. I distinctly remember him extolling its benefits and offering samples. My son's-in-law father, a surgeon, eschewed the endorsement, but many others were intrigued.

In closing, I believe Lev Tahor has been unjustly maligned by the untruths proffered by an individual whose psychological difficulties are being fed by his 15 minutes of fame. I can assert this because I know Mr. Brudzevsky. Raising unsubstantiated visions of a potential Jonestown or Branch Davidian tragedy is destroying a group that values life. Ironically, it is he who, I am told, attempted suicide in the past. Ordinarily, we would never reveal such a private matter, but we want to put these heinous accusations against Lev Tahor into perspective. Personally, we feel sorry for his problems, but his sickness is destroying too many innocent families.

I do not ask you to accept anything I have written. I do ask you to search for the truth and arrive at your own conclusions. I urge you to put Mr. Brudzevsky's accusations in context, if not also requiring a psychological evaluation of his capacity for telling the truth. Too many lives have already been needlessly disrupted.

I am willing and ready to testify before the honorable court under oath on the entire above, if the honorable court will see it necessary.

Sincerely,

Harold Boss Diane Boss

Address: 49 First Ave. Monroe, NY 10950 Tel. (845) 783-6880 Email: [email protected]

PS: On a totally different, but ancillary topic: Much is being made of Rabbi Helbrans' kidnapping conviction in the US. I would like to refer you to a link quoting a NY Times article indicating that, “The rabbi was found guilty of kidnapping, jailed for two years and deported to

3 Israel — despite testimony from Shai, who had resurfaced after two years in places like a yeshiva in France, that he had voluntarily run away after the Helbrans family showed him ”what a normal family was.”

Now 22 and living in heavily Orthodox Monsey, N.Y., Mr. Reuven repeated last week that he had been neither been abducted nor brainwashed. 'I was following the religion, not Helbrans,' he said.” http://jpupdates.com/2012/06/05/the-2001-ny-times-article-that-contradicts-the-nyt-of-2012-re garding-helbrans-of-1994/

In my estimation, Mr. Brudzevsky represents the second of Lev Tahor's major errors in judgment. They saw someone in need, tried to help, and found themselves fighting for their own existence.

4

THIS IS EXHIBIT "I" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 My name is Bonnie Wood and eight years ago I lived in the community of Lev Tahor for 2 1/2 years. I am a certified trainer of Neural Linguistic Programming; I do Psycho-Neuro Biology; I have studied and taken classes on abuse, and my son is a licensed practicing family and clinical psychologist in Seattle Washington. I have had extensive opportunity to observe the behavior of the people of this community in regard to their children, their beliefs, their practices, and their relationship with the Rebbe, Shlomo Helbrans.

To begin with, I have known Miriam Laver since she was a child. She is a loving, intelligent, caring person, and is a wonderful concerned and caring mother. I have always admired her high degree of emotional intelligence, and her ability to communicate and relate well to people. Miriam’s children are testimony to her skill as mother. On a recent visit, it was obvious her son, a precocious three-year-old, is emotionally and intellectually advanced.

During my 2 ½ plus years living in the community as well as the many times I have visited since, I have noticed beyond a doubt that the children are well taken care of. The people of this community follow the Torah, which is the old testament. They definitely put God first, family second, and the community and the Rebbe third. These people are taught that you never discipline a child when you are angry. They talk to their children and teach them not to bully as it is written in their Torah. Their methods of child rearing demonstrate the most consistent family values I’ve ever witnessed in an entire community. All teachings reflect the sound advice of the Torah.

I can't say that I have observed everyone at all times, however, I have seen most of the community in its natural state on a day-to-day basis.

Miriam Is, if anything, an example of what a good mother is. I have never seen any bruises, cuts or welts on either of her children. I have never seen any sign of abuse on her children. If all children who have a slight mark on their face were taken away from their parents, we would have no children in their birth homes. Miriam is a delight. Her mother-in-law frequently helps with the children. Her family is everything to her. She keeps them clean and addresses any health issues that they may have. They are her pride and joy. She values them so much, of course she takes good care of them. Miriam is a wonderful mother.

It appears you have heard many rumors about this group, but very little truth. I would think that your main concerns would be, is this a dangerous group and are the children abused. I am thankful that you look into these issues and I can assure you that this group is not dangerous to anybody. If the Rebbe told the group to take poison they would not listen to them him. If the Rebbe told them not to practice their Sabbath, they would think he was out of his mind and leave. These people are very intelligent as a whole. They are self thinkers as a whole. They have chosen the Rebbe, as their spiritual leader because they admire and look up to him. The only thing they worship, is God.

Regarding the community as a whole, their practices differ from other orthodox communities in subtle ways, for example, modesty in this sect would dictate that instead of covering their elbows like other Orthodox sects, they cover their wrists. Instead of covering their knees like other Orthodox groups, they cover their ankles. Instead of covering their collar bones with their clothing, they cover their necks. The reason behind these practices is to ensure they follow the laws of the Torah impeccably. This is no more dangerous than the Amish way of dress, nor is it any more abusive or harmful to anyone or anything than the Menonite practices, yet those religions are tolerated. It is simply their interpretation of the given laws of the Torah. These are harmless religious practices.

This community is not perfect however they strive every day to elevate their character and to be good people. They take time with their children to teach them good values. They treat their children extremely well. They also help one another whenever one needs help. To end, I must say that I hope you do not listen to people who try to make this group look bad out of fear of the “other,” and revenge. If their educational system is not up to par, that is another matter, and I know they would be more than willing for you to work with them to bring it up to par and fulfill whatever obligations are required by the province.

It would be criminal to take Miriam's children away from her because of a little mark on her daughter’s face. It also would make no sense. I know that you are concerned with this group especially after hearing all the things that are said about them, but I hope you take the time to investigate because upon closer examination, I know then you will also feel the way I do about these kind-hearted people. Please feel free to call me at anytime. My phone number is: (206) 678-7798. Thank you very much.

Wishing you well,

Bonnie Wood

THIS IS EXHIBIT "J" TO THE AFFIDAVIT OF MIRIAM HELBRANTS AFFIRMED JANUARY 31, 2014 With the help of Hashem

January 27, 2014

To the honorable board of directors of the Chatham-Kent Children's Aid Society. We, the undersigned, are serving as community organizers in the Lev Tahor community. We feel it is in our duty to express the sentiments of the families in our community with regards to the agency's ongoing involvement with them since their arrival to Chatham-Kent in November 2013. We will try to express their sentiments relating to the following points:

The position of the families relating the intervention of the DYP in Quebec between August 7, 2013 and November 17, 2013  Firstly, it is important to note, that the DYP of Quebec had never received a complaint of child abuse of any kind from a child of the community, nor have they ever received such complaint from anyone who claimed to observe such in a family of the community or in the community in general.  The only basis for the intervention of the DYP in the community was due to the fact that the children of the community were reported to not having an education equivalent to the Quebec Education Program (QEP).i  Quebec law dictates that children failing to study the curriculum provided by the Ministry or equivalent thereof, are considered endangered and neglected. This statute provides enough grounds

Page 1 of 26 for the Quebec Youth Protection Agency to gain full mandate over the children and their future.ii  The issue of the education system of the community was addressed by the Ministry of Education of Quebec since December 2011, and was being negotiated with the community ever since.  Much before the DYP files were opened, the community contemplated settling the education dilemma by simply leaving the province, as the Mennonite community has done earlier in 2007.iii The community has actively pursued this option since April 2013, by hiring a real estate agent to look for a suitable alternative for the community in Ontario, and following by visiting several properties in Ontario for consideration. The real estate agent also placed several classifieds in popular Ontario newspapers.iv  The education issue has prompted the DYP to raid the community. The initial raid took place on August 7, 2013, one day after the children of the community were reported to the DYP for non-complying with the local and provincial education guidelines and regulations.v  Because the community already expected the intervention of the DYP regarding the schooling issue, and because the community concerned that the intervention of the DYP will put an end to their ongoing negotiations with the Education Ministry and the local school board and ultimately force the community to act against their religious beliefs, the community hesitated whether to cooperate with the DYP on the initial raid, and proposed instead to leave Quebec in case that Quebec does not intend to respect their freedom of religion.  The DYP directors, however, mislead the families and the directors of the, and blatantly denied the fact that the raid and the request of opening investigation files are solely related to the education issue for the very same purpose of which the

Page 2 of 26 community was afraid of, namely to force the community to act against their religious beliefs, under threat of being caught up even more with the DYP. Instead, the DYP directors cause the community to believe that they will consider the education issue as a minor one and that the DYP directors will in fact contribute to the negotiations of the community with the school board in exchange for their cooperation with the DYP.vi  During the raid, The DYP workers collected information and copies of documents of all children, even those under school-age. As well they intervene in families with no any children at compulsory school age. The children were taken for medical and dental examinations, and their bodies were carefully examined. By that, the DYP directors and their workers passed the limits of intervention allowed by the law under their original mandate for intervention.  The expanding of intervention for issues not related to schooling is a serious violation of section 8 in the CANADIAN CHARTER OF RIGHTS AND FREEDOM that states: "Everyone has the right to be secured against unreasonable search or seizure."  By singling out a all group with a specific path of a religion and target them by "unreasonable search or seizure", they further violated section 15(1) in the CANADIAN CHARTER OF RIGHTS AND FREEDOM that states: "Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination and, in particular, without discrimination based on race, national or ethnic origin, colour, religion, sex, age or mental or physical disability." Obviously, the families and children of Lev Tahor were clearly discriminated because of their religion.  The permission of the families for entering the homes and conducting the unreasonable searches can not be on the defense side for the DYP, since they steadfastly refused to mention the true

Page 3 of 26 concerns that prompted the investigation.vii The nature of the investigations and the methods used by the DYP workers, also duped the families to believe that there was indeed a report of alleged child abuse (while, in fact, no genuine report ever existed to prompt such investigations).  It is important to note, that on the day-long raid, the DYP found happy and healthy children, loving parents who took good care of the children, peaceful and stable families, excellent nutrition, clean and spacious apartments, well-mannered boys and girls, and above all – a gentle and honest community that will go beyond the call of duty to ensure the quality of life for the children.  During this raid, the loving parents, confident of the level of care and intention given to the children, have bewilderedly questioned the DYP workers on their findings. The DYP workers were unable to put a finger on any specific concern, besides a small, almost invisible leak in the hallway in one of the homes, and a missing steam cover in another home (please note that this raid took place in the summer, when steams are not used).  The question begs for itself: why, if so, the investigations of the DYP continued over a span of more than three months? This question is somewhat rhetorical. The sole reason for the DYP investigations to go on for such a lengthy period of time (over three months), was not more than a strategy of the DYP to gain more legitimacy to their intervention in the community, by seeking other "concerns" besides education.viii The DYP workers were motivated to continue with investigations to drum up additional allegations of other forms of child "neglect" by each and every family to support the legitimacy of the DYP intervention in the community pertaining directly to education.ix  The DYP directors acknowledged that they were aware of Ultra- Orthodox opinion on the education system and the religious beliefs preventing the community from complying with the virtual

Page 4 of 26 wording of the regulations. (Based on a pending court decision that would affect Jewish Ultra-Orthodox communities in Quebec, the DYP declared that they understand that Ultra-orthodox families such as those in the Lev Tahor community cannot fully comply with the Quebec school curriculumx). However, the DYP directors demanded a revision to the current curriculum to include a higher standard for language, arts and mathematical studies. They required a detailed "action plan" that would be reviewed by their superiors.xi  The community explicitly stated to the DYP directors their decision that they are ready, willing and able to leave Quebec if the education issue is the real cause for concern.xii (The DYP directors later denied in court their acknowledgement of this decision;xiii however transcribed recordings of the meetings with the DYP directors which were provided to the court by the community, proved that they were, in fact, aware of the community's decision.xiv)  Another misleading by the DYP, while the directorate level of the DYP had expressed understanding of the impossibility of Lev Tahor families complying with the virtue language of the schooling regulations, their workers however expressed explicitly for individual parents that they see 'no reason' why the children of Lev Tahor will not ultimately attending public school and completing their religious studies in Sunday synagogue classes. This expression of the DYP workers for the individual parents was essential in gaining the mandate to bring up the schooling issue before the Youth court circumventing all the negotiating between the directors of the DYP and the directors of the community. To conclude this issue; the directors of DYP intentionally deceived the community in order to caught them into court proceedings rather than giving them a clear choice to implement their right of mobility granted by section 6 of the CANADIAN CHARTER OF RIGHTS AND FREEDOM.

Page 5 of 26  On numerous occasions, the DYP directors repeatedly denied to the community the fact of the education issue as being on the top of the list and actually the only legal basis of the files.xv On each meeting with the directors of the community they came up with different so-called "new concerns", none of them relevant for DYP intervention, always hinting that the education issue is on the bottom of the list.  The DYP have deceived the community by reassuring them that leaving Quebec is not necessary to resolve their issue with education, while the DYP continued their intervention in the community with the agenda to drum up allegations against each and every family.xvi  Evidence on the bias of DYP to intervene anyway in the Lev Tahor religious lifestyle, was the second raid of August 14, 2013 in which the director of the DYP in person apprehended the five young children of Mrs. Canah Alter. [See more below under the subtitle "the position of the families relating the persecution against Chanah Alter"]  The unreasonable search and investigation of the DYP, with the mission to create allegations, was on the expense of the children and the families. Their lives became stressful and chaotic. The families were repeatedly subjected to unexpected visits; children were the objects of numerous body checks multiple times on separate visits, not to speak about irrelevant questioning.xvii  For the duration of the investigation the families lived in a hostile environment. For more than three months, their quality of life, as well as their assets, schedules, privacy, and homes, were at the mercy (merciless) of the DYP's wishes and commands.xviii  In conclusion of the Quebec DYP "findings": (a) The community was under the scrutiny and discerning eyes of the Quebec Youth Protection for over three months;

Page 6 of 26 (b) The investigations were intensive, included private interviews with parents and kids, repeated body checks, medical examinations and frequent unannounced visits to each family; (c) The investigation proved there was no abuse of any kind, no drugs, no alcohol, no smoking, no violence, no neglect, no bullying, or any other forms of misconduct in the homes of these families.  Finally, The DYP notified the families of Hayon and Soleimani on November 14, 2013 they will be called to court for the purpose to enable the DYP keep their files open for further visits; the ground for this request explained to these families, as well in the court papers filed after their relocation from Quebec, was solely the issue of education.xix  The deception of the DYP regarding the education resulted in the community hastening their decision and actually leaves the province of Quebec on November 17, 2013.xx

The position of the families relating the actions of the DYP after the relocation of the community on November 17, 2013  The families of the community believe that the DYP was wrongful with opening court cases against the Hayon and Soleimani families solely based on Quebec education laws after their actual relocation to Ontario on November 18, 2013.  The families of the community believe that the later request of the DYP to return the children to Quebec was purely a political, and arguably act of revenge, to preserve their dignity.  Quebec's court order to return children to Quebec and consequently place them in foster care was triggered by the false and misleading allegations of the DYP.  Even if those allegations were valid, they should not concern child welfare agencies that comply with Ontario law. Investigative

Page 7 of 26 fairness should be considered and prevail in Ontario our new home.

The position of the families relating the involvement of the CAS of Chatham-Kent from November 2013 to January 27, 2014  The families of the community have continuously expressed their eagerness to prove their innocence by personally inviting the CAS and any government official to their homes upon their arrival to Ontario.  The families, as well the community organizers, had shown full cooperation during the following visits and investigations of the CAS.  The community organizers did voluntarily provided the CAS every change of address and all other information requested by the CAS about families of the community.  The children of Hayon, Soleimani and Kein families, had expressed to the CAS their hope and will to sit peacefully with their parents in Ontario, and asked the CAS to help and support their will and the children’s best interest in case it comes to an Ontario court's decision.  In response, the CAS has demonstrated their unwillingness to judge and act according to the best interest of children and their parents. CAS has lacked cultural and other sensitivity, and expressed indifference for the tearing apart of innocent families. This was obvious to all the families of the community for the reasons that include the following: a. Families thoroughly investigated by CAS and found to have no concerns whatsoever (Hayon, Soleimani and Kein), were later selected and targeted by CAS to be torn apart by having all the children removed from their parents and transported to another province 830 kilometers away with no consideration of their own risk assessments;

Page 8 of 26 b. The CAS was racially and culturally discriminatory by opening cases on these innocent and peaceful families for the sole "crime" they were associated with Lev Tahor; c. CAS methods and procedures to enforce provincial legal proceedings were not related to CAS affairs, obligations or responsibilities; d. Furthermore, CAS has not done their own due diligence to investigate the credibility and reality of allegations from Quebec; they simply seem eager to be Quebec’s enforcers. e. Additionally, CAS did not hesitate to open files based on allegations of which have no legal importance under the Child and Family Services Act in Ontario; f. What is more, CAS has proven their motives are to break these families by appealing court decisions in matters that do not pertain to CAS or child or social welfare affairs; g. Moreover, when the appeal regarding Rachel Kein was dismissed, CAS requested to remove Rachel's nursing infant from her mother's arms and put her into foster care in Quebec, by giving Rachel the "option" to separate from her husband, give up her own apartment, and go into foster care together with her child. h. This requirement to go live with families of another path of the religion is a serious violation of section 2 the CANADIAN CHARTER OF RIGHTS AND FREEDOM that states: "Everyone has the following fundamental freedoms: (a) freedom of conscience and religion." i. A heart rending letter from Rachel to the CAS, brought no response. This callous disregard for the best interest of children and fairness is not what had heard about Ontario prior to living here.  In the case of Helbrans-Laver, the CAS proved that the full cooperation of the entire community or the Ministry of Children

Page 9 of 26 and Youth investigation directives hardly matters. In this case, the CAS has shown a seeming blind hate towards the entire community: a. By considering the mark as "unexplained injury", despite the unanimous testimonies of numerous other community members, all of which fully matched with the version of both the mother and the father; b. By rejecting the comments and testimonies of other responsible community members, all of which the mother and father are well known to them as excellent parents that taking well care of their children, and quite the opposite of such that will harm any human being on the earth; c. By refusing to conduct a cleaning test to distinguish between a ink stain and a bruise; d. By refusing the opinion of the police investigator that no abuse can be suspicions in this case; e. By refusing the opinion of the emergency room doctor that no abuse or neglect can be related to this mark; f. By refusing to place the children with a family relative or any family in the Lev Tahor community; g. By prosecuting an innocent mom with allegations not related to her personally, only on her association with the Lev Tahor community; h. By prosecuting the entire community with decisions of other courts, although these judgments and decisions were clearly applying only to particular families (Hayon and Soleimani), and absolutely not to the entire community or any other family in the community; i. By fabricating an extreme and broad libel, that physical discipline is "acceptable" in the community.  In light of the Helbrans-Laver case, the feeling of each and every family of the community is that their "case" is already waiting;

Page 10 of 26 further visits of the CAS at their homes are considered by the families just as preparation to make up additional allegations on each family specifically, while the CAS already described them long before as neglecting or dangerous for the sole "crime" of their relation to the Lev Tahor community.  The systematic approach and methods used by CAS workers has left no doubt by any of the families of the community that the motives of the CAS are to maintain as many open files for long periods of time, to have the ability to intervene in private family and community life. a. CAS proved their motives were to open cases by inquiring in private family and communal affairs that had no relevance to the safety of children. By this, CAS has also violated parents' right over their children. b. During repeating unannounced visits, the CAS workers had demonstrated their motives by focusing their investigations on irrelevant topics and on irrelevant individuals. c. Requests of the CAS directors to the community organizers also proved unfair intervene in the community life. d. CAS has abused their power by issuing unlawful and unethical orders to individuals not related to child protection concerns, including Mrs. Chana Alter-Helbrans, which is well known to the entire community as wonderful and very special parent, with no any consideration of risk for children, but was targeted by CAS workers only for being associated with Lev Tahor. [See more below under the subtitle "the position of the families relating the persecution against Chanah Alter"] e. CAS workers also used the agreement of voluntarily measures with the Helbrans-Laver to issue unlawful orders. f. CAS proved that arguments regarding unfair orders are not acceptable and will never change their position.

Page 11 of 26  Additionally, the families have proof that the CAS is corresponding and collaborating with political enemy's which are well known to have clear motives to destroy the community for innocence, such as the Israeli authorities and/or their representatives in Canada.  Until recently, the community has taken measures to defend the CAS and maintain their dignity in the Media even after they received repeating shocks and bitterness from the unacceptable behavior of the CAS towards them.

The position of the families relating the persecution against Chanah Alter  The families of the community are convinced that the painful apprehension of the five children of Chanah Alter by Denis Baraby, Director of DYP, on August 14, 2013, had no legitimacy by any legal point of view. To make a long story short, we will only mention a few highlight's: a. The divorce and custody case of Chana Alter vs. Nathan Helbrans was before the Superior Court of Canada. b. The DYP already knew about the case for more than a year while probably did not find any justification for intervention. c. The DYP hurried to intervene in the Alter-Helbrans case after the superior court had commenced proceedings. The intervention of DYP was never related to the best interest of the children, rather it was initiated in order to circumvent the superior court that is under the Canadian federal jurisdiction which grants the constitutional right of freedom of religion. The DYP were determined to bring the case before the provincial youth court where the religious education of Lev Tahor can be questioned since they have different approach on freedom of religion.

Page 12 of 26 d. The DYP clearly mislead Chana Alter by filling court documents requesting permission for supervised visits for the father, while the children should stay with their mom;xxi and additionally, Madam Suzanne Tye, a social worker for the DYP, confirmed to the mother that she evaluates Chana as a mother who is taking well care of her children;xxii and then upon the arrival of Chanah to the courthouse in Sainte- Jerome, the director of the DYP Mr. Denis Baraby in person, accompanied by police officers, broke into the home of Chana in Sainte-Agathe, and apprehended the children. e. The explanation given by Denis Baraby for the apprehension without a warrant when the parents are in front of a judge, was strange for itself: the "order" for apprehension was directed by children's lawyer. (Please note that the children's lawyer never met Chana or any of her children). f. The court for provisionally measures was postponed just after the DYP finished with their briefing, and than the court "finished" for the day and supposedly there was no court dates available in the next 2 months (twice the maximum time allowed for provisional measures), while not giving the mother nor her lawyer even an opportunity to express a single sentence in her defense about the provisionally measures. g. After 60 days, the DYP performed an evaluation about the case which was only denouncing the beliefs of Lev Tahor while not concentering in the best interest of the children. They did not stop short from denouncing the approach of Lev Tahor regarding the state of Isreal, Regarding modest clothing and even regarding prayer times. h. The evaluation of the social worker named Suzanne Tye was manipulated in a roused way. She found it necessary to mention a case of the Grand Rabbi in NY back in 1992 not related to the custody case but contributing to illustrate the

Page 13 of 26 old controversial history of Lev Tahor. On the other hand, she did not fell it necessary to mention even one word about a visit in which the father of the kids (Nathan Helbrans) tried to abduct them and ending up in the fathers detention and criminal charges. Why was this fact ignored in the Suzanne's evaluation? Because the father was the source of numerous blood libel style allegations against Lev Tahor and the story will cause the court to reconsider all the allegations based on his words. i. In that opportunity of the evaluation hearing, Chanah and her lawyer where again deprived from the right of defense with the excuse that the schedule of the court just finished for the day at the moment the DYP finished to address the court.  The DYP did not allow kosher food from Lev Tahor to be brought to the children, even that the oldest daughter of Chanah repeatedly requested it.  When the oldest daughter of Chanah started to limit her food menu and requested the kosher food from her mother, the DYP choose to threaten the mother to order the girl to not obey her religion instead of simply allowing the food sent by the mother to her child.  The DYP did not take any action when the oldest daughter of Chanah reported to them that she is being kicked by family members of the foster family which is hostile to Lev Tahor.  Finally, after the Lev Tahor community moved from Quebec to Ontario, the DYP worker, Suzanne Tye, asked Chanah Alter to commit herself not to move with her family and instead to go away from the Lev Tahor community. When she protested over the DYP involving in her private decisions, the DYP worker Suzanne Tye decided on their own hands to deprive her from access rights and to ban even telephone conversation to the children.

Page 14 of 26  The DYP also provided false information about Chanah Alter to the CAS of Chatham-Kent which led to the CAS ordering Chanah not to be unsupervised with any child.  The families of the community explained to the CAS the illogic of their order and defied their order at the strongest term possible.  The CAS threatened to open files against each family that will not be committed not to let Chanah Alter unsupervised with children.  This threat was seen by all women in the community as another injustice from the DYP and the CAS against any innocent individual loyal to Lev Tahor and contributes to the decision to stop the coziness with the CAS workers.

Conclusion  After roughly two months of full cooperation with CAS of Chatham-Kent, The families lost their trust in the CAS workers; they deeply believe that further cooperation with CAS would only empowered them to abuse their power and exert unjustifiable control over the community. It has become extremely difficult to trust that CAS can be partners with us in the best interest of our children.  The families are convinced that further investigations by the CAS will only prove destructive to the innocent families, and will only cause emotional harm to the children.  The families believe that the CAS of Chatham-Kent already had the opportunity to verify by themselves that there is No abuse, No neglect, No crimes, and No any reason for intervention in the private life of these families.  The families strongly believe that the CAS should not have any concern with trusting the parents in the community as responsible caregivers for their families and children.  The families also believe that the parents in the community, as well the community organizers, are reliable and honest enough

Page 15 of 26 not to tolerate child abuse or neglect within the community; they would be the first to bring child abusers to justice. The community repeats once again its clear statement, as follows:

"If someone abuses a child, it is a crime against humanity and against the Torah. If someone forces a person into marriage, it is also a crime against humanity and against the Torah. If we know someone like this in our community, we will be the first to hold him responsible for his actions." (www.levtahor.ca and other media publications).

Regarding the future  The families of the Lev Tahor community are seeking measures to respectfully withdraw the intervention and involvement of CAS in their private peaceful lives.  The families prefer to avoid any conflict with the CAS of Chatham-Kent and its workers.  The families are requesting the CAS, as follows: a. To drop and close all the complaints, allegations, charges, court cases and any kind of legal preceding's against the Hayon, Soleimani, Kein and Helbrans-Laver families unless there are reports of risk; b. To close permanently all the files related to the families of the Lev Tahor community, and terminate their visits and investigations unless there are reports of risk; c. To terminate immediately the unfair persecution against Mrs. Chana Alter-Helbrans unless there are reports of risk.  In turn, the community for its part, will agree as follows: a. Immediately terminate all the complaints filed against the CAS of Chatham-Kent and/or its workers;

Page 16 of 26 b. Not to file in the future any complaint or lawsuit against the CAS of Chatham-Kent and/or its workers regarding their involvement between November 18, 2013 and January 27, 2014; c. Not to request the CAS to recover the cost of the Soleimani, Kein and Helbrans-Laver court cases; d. Not to publish the recordings/photos and written detailed reports of the CAS visits at the homes of the families; e. To continue and maintain the respect of the CAS in public relations and not expose or publish negative statements or remarks in the media against the CAS of Chatham-Kent and/or its workers.

Sincerely yours,

______Mayer Rosner Uriel Goldman Nachman Helbrans Community organizer Community organizer Community organizer

Page 17 of 26 Endnotes

i One of the sources: testimony by Suzanne Tye, a social worker for the DYP, in a Quebec hearing on November 27, 2013: "SUZANNE TYE: […] On August 6 or about that time, all the children were reported for non attending school, and this allowed us to start knocking on doors. DANIL VILLENEUVE: August 6, 2013? SUZANNE TYE: Yes. We were several interveners and we went to the community, and we made sure that all of the children were reported, and that allowed us to see everyone."

ii The "Quebec Youth Protection Act" (Division I "Security and development of a child" Paragraph 38) reads as follows: "For the purposes of this Act, the security or development of a child is considered to be in anger if the child is abandoned, neglected . . . . In this Act, . . . (b) “neglect” refers to . . . (iii) … or failing to take the necessary steps to provide the child with schooling; . . . "

In Paragraph 38.1 the Act reads as follows: "The security or development of a child may be considered to be in danger where… (b) he is of school age and does not attend school, or is frequently absent without reason;.."

The schooling of the children provided in the community's education framework was excellent, but it was unable to gain the legal definition of "schooling" according to the Quebec Education Act, section 15(4).

This act is more elaborately explained in the Ministry of Education's policy on homeschooling:

"Parents who home school their children are responsible for ensuring that they receive instruction and benefit from an educational experience equivalent to what is provided at school, according to an evaluation made by or for the school board."

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“Equivalent” may be interpreted to mean that the instruction and educational experience must give the child sufficient knowledge and competencies so that the child may enter or reenter the public or private school system."

"To this end, parents must ensure that their child achieves the learning objectives set out in the programs in effect in Quebec schools, or develops the competencies specified by the Quebec Education Program (QEP)."

Due to the religious observance of Ultra-Orthodoxy and subsequently these families, certain secular subjects such as evolution and sexuality studies are not allowed. Therefore, the children of the community were legally considered "neglected" and in "danger" for the mere fact of not studying the Quebec curriculum. The DYP now has legal grounds to intervene on behalf of the "wellbeing" and "safety" of the children.

Practically speaking, according to Quebec law the DYP now has the full mandate over the children. If the parents fail to comply with the Quebec education act as these families have done, "safety measures" to avoid further "neglect" may include seizing children and placing them in foster care. In Quebec, placing children in foster care for such reasons would ensure the children would not be "neglected".

The only reason that seizer of children for mere the schooling issue is still considered uncommon in Quebec, is due to the fact that parents will rather give up for all education requirements in order to avoid the DYP intervene in their private life. However, this was not likely to be the case by the families of the Lev Tahor community where the schooling issue is one of the most important parts of their religion.

iii An article at the Toronto Star, Sep 29, 2007, Reported:

ROXTON FALLS, Que.[…] The soft-spoken Mennonite deacon's small community is locked in a year-old fight with Quebec's education ministry over their desire to teach their children according to their faith. More than 30 of the group's women and school-aged children have gone into self-imposed exile in Alexandria, Ont., just over the Quebec-Ontario border, to ensure they can do so.

The Quebec government mandates that they follow the law, which includes teaching the official curriculum with government-certified teachers.

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But the Mennonite interpretation of the Bible clashes with what they see as Quebec's increasingly secular curriculum and with parents' demand that those who teach their children pass up university education and provincial certification.

"We feel that (higher education) becomes a God. If you aspire to fame and fortune and everything else that goes with it, that's against Christian faith. So then they ask us to have certified teachers that ... come out of university and that in itself, that's not what our faith teaches," he says.

"That's not the role model we want for our children. That's the line we're at with the government right now. That's the line that's drawn."[…]

Faced with a local news report on the illegal Mennonite school, Quebec's education minister warned last November that the community must follow the curriculum and hire a certified teacher or face being shut down.

Locals feared that child protection workers would intervene to break up the families and there were concerns the warning to the Mennonites was a prelude to a crackdown on illegal faith-based schools in the province."

iv One of the sources: Affidavit of a Henri Primeau, a licensed real estate agent in Quebec.

v One of the sources: testimony by Suzanne Tye, a social worker for the DYP, in a Quebec hearing on November 27, 2013.

vi One of the sources: recordings of discussions between the directors of the DYP, including Denis Baraby, and the community, during the raid of August 7, 2013.

vii One of the sources: recordings of discussions between the directors of the DYP, including Denis Baraby, and the community, during the raid August 7, 2013.

viii While the original goal of the DYP was not to seize the children and rather they preferred to change the religious lifestyle of the community trough the intervention of the Quebec Youth court in the education (source: testimony by Suzanne Tye, a social worker for the DYP, in a Quebec hearing on November 27, 2013) it was one of their tactics to maintain the possibility of seizing the children as an option in order that the

Page 20 of 26 parents and the community should not resist the intervention (one of the sources: recordings of meeting between Denis Baraby, director of DYP, and directors of the community, including the Grand Rabbi of Lev Tahor, on August 14, 2013).

Obviously, if the DYP seized any children solely because of not being educated according to the Quebec curriculum, the DYP would be extremely criticized for not considering the best interests of the child and for destroying families for a relatively minor concern that could be rectified in another province. To avoid the negative publicity, there must be more grounds for the seizure of the child.

As was testified by Suzanne Tye, a social worker for the DYP, in a Quebec hearing on November 27, 2013, the social workers were ordered and motivated to search for other forms of physical and/or emotional neglect' from each family, which would serve as the basis and the legitimate reasoning behind a seizure of the children, while all along the education issue is the only basis of legal mandate for intervention.

In her wording:

"Well the non-attendance at school was the sub-text that we used for the entire group of children, but the farther we advanced in our elevations, there were other sub-text that were added specifically.

We started with one family and then … family by family, and it wad in this context that we met the Hayon and Soleimani families."

ix One of the sources: testimony by Suzanne Tye, a social worker for the DYP, in a Quebec hearing on November 27, 2013.

x The Jewish Ultra-orthodox communities in Quebec are facing pressure to comply with Québec's secular education curriculum, since 2006.

The largest Ultra-Orthodox community in Quebec is the Satmar community, with roughly 350 families.

After four years of negotiations with the Satmar Yeshiva, the Education Ministry went to court seeking a permanent injunction to close the Yeshiva and a temporary one

Page 21 of 26 to do so immediately. The Satmar Yeshiva Battled in Court to stay open, claiming that their freedom of religion will be violated, since their religion is forbidding them from teaching their children parts of the secular curriculum, namely, the subjects of evolution and parts of social studies.

For the temporary injunction, the Education Ministry has lost the case in the first round in the superior court of justice on September 7, 2011. (In the court decision, the court explained in detail the approach of experts why an enforcement of the education act on Ultra-Orthodox Jews constitutes a breach in the constitutional right for freedom of religion). In regards to the permanent closure, the court has been scheduled for November 2014.

Although the court proceedings are against Satmar, the verdict will affect all the Ultra-Orthodox communities sharing the same values, since the argument of the Satmar Yeshiva by virtue of the freedom of religion applies on the same way to all other Jewish Ultra-Orthodox communities as well. However if Satmar will lose their case, Lev Tahor would still have their chance, taking into account their stricter and more consistent approach of practicing original Judaism.

xi One of the sources: recordings of meetings between the directors of the DYP, including Denis Baraby, and the community.

xii Source: recordings of numerous meetings between the directors of the DYP, including Denis Baraby and Alinne Baeume, and the community directors.

xiii Affidavit of Alinne Baeume, Director of the DYP of Sainte-Agathe-des-Monts.

xiv Affidavit of Mayer Rosner.

xv Source: recordings of numerous meetings between the directors of the DYP, including Denis Baraby and Alinne Baeume, and the community.

xvi Source: recordings of numerous meetings between the directors of the DYP, including Denis Baraby and Alinne Baeume, and the community.

xvii The DYP has systemized the investigation in a way that disturbed family life and caused disturbance to the peaceful and quiet lifestyle they enjoyed prior to their arrival. The families were now forced to being accustomed to a new schedule and living

Page 22 of 26 standards. Alternating patterns of abuse by DYP was standard. Weekly home visits and a subsequent "invitation" to the office the day after for day-long questioning was the now the norm. This pattern rotated among the families, there was always the anxious feeling that "you are next". The way the DYP "manhandled" the families were despicable and heartless.

The day-long questioning at the DYP office also included intensive questioning regarding the general way of life of the community and their religious customs. Prayer schedules, Laws of "Niddah" and "Kashruth" were among the topics addressed by the DYP for each family individually. These were the topics that took up precious family time and caused children to be absent from school.

Parents were also repeatedly investigated and interviewed regarding every possible aspect on their private lives, topics that had no relation to the concern or wellbeing of the children. Ridiculous as it may sound, parents were questioned on their intimate marital relationships, woman were queried on the frequency of their visits to the ritual bath "Mikvah", financial information, bank statements, and immigration documents, were also demanded by social workers. The social workers have also demanded and ordered parents to sign release forms of their own medical records, besides for the children's.

Irrelevant information regarding family history from years gone by were also of special importance to social workers, A 46 year old father was also questioned as to who educated him on intimate marital relations. Mundane questions, such as whether the husband gives the wife a bank card or cash for shopping, or a 17 year old spouse being asked whether her husband is a good person and being pressed to mention at least one bad thing about him.

The DYP also showed utter disregard for family and religious values. Their private interviews with children should have been limited to matters that are of concern. Unfortunately, they abused their power by asking the children rhetorical questions, such as asking teenage boys whether they agree to chose a girlfriend by their own and vice versa. These questions were asked long after the initial visits, the social workers were very much aware that the children are Ultra-Orthodox, and gender segregation is an

Page 23 of 26 integral part of the religion. The children reported to have been quite perplexed and intimidated by these questions.

xviii Families with many children were tasked with the impossible. The social workers explicitly noted that at all times, the homes are expected to be tidy in the same manner as a home without any children, or face the possibility of maintaining such a home – empty of children.

According to our humble opinion, complete home makeovers and cosmetic touchups are decided privately by families, not welfare agencies. In a meeting with the community a week after the first raid On August 14, 2013, the DYP reported their "horrible" findings and demands:

Homes required renovations, and children were found to have cavities in their teeth.

Needless to say, all children were treated regularly by local dentists. To satisfy the DYP, the community created an initiative to be cavity free although the dentists recommended waiting out the treatment over a longer period of time in cases where cavities were more frequent.

The homes were relatively in good condition. They posed no danger nor did they disturb the quality of life. If they indeed posed a danger, the DYP would not think twice before pouncing on their prey… underage children. Nonetheless, the DYP felt it was their duty to address those "concerns". They set a date for the community to come up with a proposal and "action plan" to rectify the situation in the near future. The deadline for submitting the proposal and action plan was three weeks later on September 3, 2013. This date corresponds to the Jewish New Year holidays, a month long celebration which is costly, and involves many hours of advance preparation such as building a "Sukkah", cooking and baking among other activities. This time of year keeps many Orthodox families busy all day, and part of the night with prep work.

Hoping the DYP would be satisfied and ultimately leave them alone, the families decided to go beyond their line of duty to meet and beat the demands of the DYP. Disregarding the hectic holiday season, and the flurry of preparation it involves, the

Page 24 of 26 families have feverishly painted and plastered their homes. A rigorous makeover was evident in all the homes. Replacements were favored over minor repairs. On the date the deadline for the proposal was set, the community was proud to present a report on the concerns that were already addressed and entirely resolved. There were hardly any concerns left to present a proposal and action plan. The amount of work completed in such a short timeframe is mind boggling. Definitely good for a resume…

Between allegations, it seemed that the DYP was working very hard to drum up more accusations and allegations, invading body checks were a common practice. Hoping to find bruises and other marks of injury, they settled on disproportionately addressing concerns of toenail fungus.

Although this accusation was senseless, because the families never avoided or neglected medical care; children with toenail fungus were always well treated at the local Sainte-Agathe clinic, some families chose to take treatment to the next level by traveling to Montreal and having their kids treated by specialists in the field. The families did not require nor did they solicit advice or opinion from social workers on this issue. Nevertheless, because this issue was addressed by the DYP, the families went beyond their call of duty to satisfy the agency by organizing a costly venture and hired Dr. Rachel Rubinstein, one of the most respected and well-known dermatologists from Montreal. She spent a full day in Sainte-Agathe-des-Monts and examined the children of the community.

Dr. Rubinstein's conclusion is very clear explained in her letter from January 5, 2014:

"I found the children to be clean, well-cared for and behaving appropriately, I was impressed by the warmth of the community and concern of the parents for the well-being of their children…"

"These are typical clinical problems I routinely encounter in my dermatologic practice; these are relatively benign conditions, many of which spontaneously resolve in early adulthood. It is important that I emphasize, unequivocally, that these problems do not reflect parental neglect or abuse. As

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such, there is absolutely no indication for intervention by child welfare authorities regarding this minor skin conditions." (See attachment...).

xix All the other "issues", as melatonium or fungus, were irrelevant and have no any validity in youth court. The DYP mentioned this "issues" for the sole purpose to enable them to claim that "It is not just about education"… xx xxi Source: motion of the DYP to the provincial court on August 9, 2013.

xxii Source: recording of conversation between Suzanne Tye, a social worker for the DYP, and Mrs. Chana Alter, on August 7, 2013.

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